Interpretation Response #14-0204
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
March 6, 2015
Ms. Amanda B. Foskey
Mechanical Engineer Asc.-ICCB
Lockheed Martin Space Systems Company, SWFLANT
Kings Bay, GA 31547
Ref. No. 14-0204
Dear Ms. Foskey:
This responds to your June 26, 2014 email requesting clarification of the labeling requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you request clarification on proper labeling of your package containing a Division 1.4B explosive.
In your email, you describe a combination packaging containing Division 1.4B explosive materials consisting of a sealed jar, inner packaging placed in a folding paperboard box outer packaging. You then overpack the individual packages in a larger fiberboard box for shipment.
It is your understanding that the outer fiberboard box (i.e., the overpack) must be labeled with the Division 1.4B explosive label. However, you ask if you are required to label the outer paperboard boxes that the jars are packed in as well as the jars themselves? Additionally, you ask if there is any instance where using an explosive label smaller than the dimensions specified in § 172.407(c) is acceptable?
Your understanding is correct. Section 173.25(a)(2) requires an overpack to be labeled, unless the labels representative of the hazardous material in the overpack are visible. Therefore, because the paperboard boxes placed in the fiberboard box overpack are not visible, the fiberboard box must be labeled. Additionally, the outer packaging of a combination packaging must be labeled in accordance with §172.400(a). However, the inner packagings of combination packagings are not required to be labeled. Thus, the sealed jar that the Division 1.4B explosive is contained in is not required to be labeled. Finally, the label is required to be a minimum of 100mm x 100mm in accordance with § 172.407 unless labeling in accordance with authorized international standards that allow label size modifications.
I hope this answers your inquiry. If you need additional assistance, please contact this Office at 202-366-8553.
Sincerely,
Dirk Der Kinderen
Acting Chief, Standards Development Branch
Standards and Rulemaking Division
172.407(c), 173.25(a)(2), 172.400(a), 172.407
Regulation Sections
| Section | Subject |
|---|---|
| § 172.400 | General labeling requirements |