Regulatory Center of Excellence — Hazardous Materials Safety Interpretation

Page 1S. Departmen f Transportatio Special Programs Research and Vashington, D.O Mashington D.C. 20 Administration JAN 27 2000 Mr. William O. Gramer 3M Package Engineering, Ref. No: 00-0027 Regulatory Center of Excellence 3M Center 224-1E-09 St. Paul, MN 55144-1000 Dear Mr. Gramer: This is in response to your letter regarding the orientation arrow markings that are required on certain packages of liquid hazardous materials under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically you ask whether § 172.312 prohibits the placement of arrows for purposes other than orientation on packages containing liquid hazardous materials. The answer is yes. As provided by § 172.312, each non-bulk combination package having inner packagings containing liquid hazardous materials must be packed with closures upward, and legibly marked with package orientation markings. Additionally, arrows for purposes other than indicating proper orientation may not be displayed on a package containing a liquid hazardous material. I hope this information is helpful. Sincerely, When Hills, Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 000027 172.312#

Page 201/13 :00 11:34 ID:3M Package Eng 224-1E FAX: 1-651-736-5983 PAGE 1 3M Package Engineering 3M Center Building 224-1E-09 St. Paul, MN 55144-1000 5-11-9921 Lavalle To Texwitze LARim Edward Mazzulio. Director. Fat 20₴ Research and Special Progranx Administration. $ 10 6178.312 Office of Hazardous Materials Standards - 360-302 am bill GRANTER ЗМ W'ashington. DC. 20590-0001 400 7' St SW; DHM-10 00 - 0027 in 1- 736-1407 Request for Interpretation concerning the use of up-arrows": 6Augl 998 Dear Mr. Mazzulio. 'orientation arrows' on combination packages containing liquid dangerous goods (hazardous materials) in It is our understanding that the Hazardous Materials Regulations (FIMR) do not allow placement of violation of the HMR. according to 49CFR172.312, and at best is misleading to dangerous goods package articles or containers which have no 'upward' orientation. To display such marking appears to be a handlers for whom the arrows are intended. In 172.312(b) we see that for liquid dangerous goods packages, "... arrows for purposes other than indicating proper package orientation may not be displayed...", 172.312(a)(1) specifically requires liquid- carrying dangerous goods packages to be oriented, or "...packed with closures upward" during transport. receptacles with closures capable of application and removal by the filler and user. It is generally In 172.312 (c) orientation arrows are generally required on combination packages of liquid-carrying inner removed to allow emptying or other applications, the closures do not form a 'permanent' or 'welded- understaod that because these type of closures (e.g. screwtop, etc) are applied after filling and may be hermetic' seal, and thus, pose a possible means of liquid leakage from the outer package. An 'upward risk of leakage in transport. package orientation' clearly exists and is therefore communicated fo the package handler so as to minimize or no closures at all, there is therefore no 'upward' orientation and the requirement to label a package with Paragraphs 172.312(c)(4) and (5) clearly state that when inner packagings have no such removable closures arrows "...pointing in the correct upright direction. [172.312(a)(2)" does not apply. The reason for this reguirement seems self-evident - these types of packages have no such 'closure orientation'. As paragraphs (4) and (5) seem to state, 'articles" and "inners' which are "..leak-tight in all orientations..." and which have "...hermetically sealed..." closures have no 'upward' orientation. As such, these type packages are not label the package as having such an orientation "...pointing in the correct upright direction. [172312(ak2))" tested and designed for shipment in a specific orientation to minimize leakage from closures. Therefore, to would be incorrect. Further, it seems that to label these packages as such could be misleading to handlers of the package as is the concern in paragraph (b). To apply arrows to such packages would not be for proper orientation of the inner closures (none exist), and thus may be "...for purposes other than indicating proper package orientation" and therefore may "... not be displayed..." [172,312(b)]. This seems to mean displaying such arrows would not be "optional". as may be the case of small quantity exceptions stated in (c)(2) and (3). that up-arrows on combination packaging containing liquids in "... manufactured articles or hermetically- Would you please clarify whether our understanding as stated in paragraph one is correct? Specifically: sealed inner packaging..." having no upward closure orientation are not allowed by 49CFR172.312. Sincerely: William O Gramer. Lead Engincer 3M Package Engineering. Regulatory C'enter of Excellence 3M Center 224-1E-09 (651) 736-1407 St. Paul MN 55144-1000 RE-SENT- - 13 JAN 2000. -.. this will not be Please aduise if answened, on if it ahuande has heer.#