Dangerous Goods of America — Hazardous Materials Safety Interpretation

Page 1f Transportatio .S. Departmen 400 Seventh St., S.W. Washington, D.C. 20590 Research and FEB 12 2001 Administrations Ref. No. 00-0273 Mr. Eddie Deveaux Dangerous Goods of America P.O. Box 590888 Miami, FL 33159 Dear Mr. Deveaux: This is in response to your letter and subsequent telephone conversation with a member of my staff requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) with regard to the requirements for the proper orientation of labels on packagings containing hazardous materials. Your understanding of the terms, "diamond (square-on-point)" in the HMR and "set at an angle of 45°" in the International Civil Aviation Organization's Technical Instructions for the Safe Transport of Dangerous Goods by Air, is that they do not have the same meaning. The terms "a 45 degree angle" and "diamond (square-on-point)" are synonymous and refer to the orientation of the label design for the placement of the pictorial symbol, text, or division number and compatibility group. Section 172.406 addresses the placement of labels on packages. The HMR do not prohibit the placement of hazard warning labels in an orientation where the square-on-point is located with its flat sides parallel to the sides of the packages. The labels may be placed square-on-side when square-on-point is not practicable. I hope this information is helpful. Please contact us if you have additional questions. Sincerely, Hither michels Hattie I. Mitchell, Chief Regulatory Review and Reinvention Office of Hazardous Materials Standards 000273#

Page 2DANGEROUS GOODS OF AMERICA McInture 8172.407 PO BOX 590888 + MIAMI, FL 33159-0888 + USA abelina -MAIL: info@dangerousgo0d3.ne3 WE SITE: www.dangerousgoods.nep0-0277 Phone (305) 871-3313 + Fax (305) 871-1388 September 26, 2000 US Department of Transportation RSPA (DHM-10) 400 Seventh St. S.W. Washington, D.C. 20590 Mr. Jeffrey Furr. Dear Mr. Furr: I would greatly appreciate it if you could clarify the proper placement, affixation, and orientation of labels on packages containing hazardous material being shipped domestically and internationally via air transport. According to 49 CFR 172.406 the requirements do not prohibit the placement of labels at square on point; however the illustration used in 49 CFR 172.411 thru 172.446, clearly shows the labels set at 45 degree angle (on diamond point). According to ICAO 3.4.1.1. it clearly states class hazard labels MUST conform to the following specifications: * They must be in the form of a square with minimum dimensions of 100mm x 100mm, "set at an angle of 45 degree (diamond shape)". Furthermore, IATA 7.2.2.2 (types of labels) also clearly states that a hazard label in shape of a square set at 45 degree angle which are required for most dangerous goods in all classes. Based on IATA and ICAO regulations please inform me as to which appropriate authority IATAICAO, or DOT(49CFR), takes precederice in regards to domestic and/or international fixation, and orientatio hipment containing hazardous material via air transport in reference to proper placemen Awaiting your reply, Sincerely, Eddie Deveaux Consultant OFFICE & WAREHOUSE FACILITIES + 1651 NW 68'H HAVE + CARGO BLDG 706 • SUTE 213#