Paul Reamy — Hazardous Materials Safety Interpretation

Page 1U.S. Department Research and of Transportation 400 Seventh St., S.W. SEP 2 4 2002 Washington, D.C. 20590 Special Programs Administration Mr. Paul Reamy 504 Misty Lane ... 72 Reference No. 02-0207 North Fort Myers, FL 33903 ::"! Dear Mr. Reamy: This is in response to your July 30, 2002 letter asking if hazard warning labels are required to be positioned in a square-on-point (diamond) configuration under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) and the International Civil Aviation Organizations Technical Instructions on the Transport of Dangerous Goods (ICAO Technical Instructions). The answer is no. While it is the intent of these regulations that a label be oriented square-on- point on a package when possible, the requirements in 49 CFR 172:406 and Sections 3.2 and 3.4 of the ICAO Technical Instructions 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 package. I hope this satisfies your request. Sincerely, Hothe 2: mittell Hattie L. Mitchell, Chief Regulatory Review and Reinvention Office of Hazardous Materials Standards 020207 172,406#

Page 2Ed monson $ 172.406 July 30, 2002 Labelina Mr. Edward I. Mazullo, Director Office of Hazardous Materials Standards, DHM 10 12-0201 Research and Special Programs Administration 400 7th Street S.W. Washington, DC, 20590 Dear Ed; It is my understanding that the current labeling requirements in 49 CFR Subpart E of the Hazardous Materials Regulations do not require that hazard labels be applied so as to be my interpretation? point on point. That is, hazard labels may be applied square on square. Am I correct in Would the same be true of the labeling requirements of the International Civil Aviation Organizations Technical Instructions(ICAO)? Section 3.4.1.1 in the ICAO states in part " Class labels must conform to the following SPECIFICATIONS: They must be in the form of a square with minimum dimensions of 50mmx50mm may be used on packages containing infectious substances where the 100mm, set at an angle of 45 degrees (diamond shaped) except that labels of packages are of dimensions such that they can only bear smaller labels" point to point ? Does RSPA interpret this verbiage in ICAO to mean thät hazard labels must be applied Thanks so much for your time and the time of your staff in considering these questions. An early response would be appreciated. Sincerely; rata Paul Reamy 504 Misty Lane (239) 656-7005 North Fort Myers, Florida 33903 Fax: (239) 656-0731 E-mail: thereamys1@aol.com#