{"operation":"document","citation":"98-0131","title":"Saf-T-Pak, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1998-09-22","effective_on":null,"summary":"98-0131 response to Saf-T-Pak, Inc. concerning 173.196.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-98-0131.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-98-0131.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-98-0131","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/1998/980131.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\n100 Seventh Street, S.W.\nVashington, D.C. 2059(\nAFP 2 2 1998\nMr. Eric Cook\nSat-I-Pak, Inc.\nRef. No. 98-0131\n101, 17872-106 Avenue\nEdmonton, Alberta\nCANADA\nT5S 1V4\nDear Mr. Cook:\nThis is in response to your letter dated June 2, 1998,\nregarding the marking requirements for infectious substance\npackagings manufactured in the United States.\nYour\nquestions have been paraphrased and answered as follows.\nQ1. Is it correct that a UN specification mark is not\nrequired on packaging manufactured or used in the\nUnited States for infectious substances?\nA1.\nYes.\nthe\nInfectious substance packagings manufactured in\nUnited States are not required to have package\nspecification markings under the Hazardous Materials\nRegulations\n(HMR; 49 CFR Part 171-180). As you state\nin your letter, § 178.609 (i)\nmeet the test requirements in that section from the\nexcepts packagings that\nrequirements of Subpart N of Part 178, except for\nInfectious substance packages transported in the United\nStates by aircraft under § 171.11, or by vessel under\n171.12, must be marked with the appropriate UN\nspecification mark. International markings\nfor such\npackagings, including the markings required under the\nInternational Civil Aviation Organizations Technical\nInstructions for the Transport of Dangerous Goods by\nAir (ICAO Technical Instructions) and the International\nMaritime Dangerous Goods Code (IMDG Code), are\nacceptable to the DOT provided test records show that\nthe test requirements of § 178.609 have been met.\nQ2. If a hazardous materials packaging manufacturer in the\nUnited States were to put a UN specification mark on an\ninfectious substance packaging manufactured in the\nUnited States, what would this marking designate?\n\n<<<PAGE 2>>>\n\nA2.\nIf the mark is as prescribed in the ICAO Technical\nInstructions or the IMDG Code, the mark designates that\nthe packaging conforms to the UN specification\npackaging criteria contained in those regulations.\nAlso, enclosed is a recently published advance notice\nrequirements.\nof proposed rulemaking concerning infectious substance\nI hope this satisfies your request.\nSincerely,\nHattie I. Mitchell, Chief\nRegulatory Review and Reinvention\nOffice of\nHazardous Materials Standards\nEnclosure\n2\n\n<<<PAGE 3>>>\n\n30ch\nSAFA PAK®\n19XX\nAnnisceras\n190%\nSAF PAK\nINC.\nJune 2, 1998\nmack\nEd Mazzullo\nUS Department of Transportation\nFile 173,196\nResearch and Special Programs Administration\nOffice of Hazardous Materials Standards\n400 Seventh Street, S.W.,\nWashington, D.C. 20590\nDear Mr. Mazzullo:\ngoods. Currently we are preparing to set up a manufacturing facility in the US and plan to have a\nSaf-T-Pak, Inc. manufactures UN Specification packaging for transporting Class 6.2 dangerous\nUS facility test our packaging. I wish to inquire about US requirements for specification markings\non packaging for Class 6.2 dangerous goods manufactured and used in the US. My question is in\n1.1 am aware of UN and ICAO requirements for specification marking however, is it correct\nthe US for Class 6.2 Dangerous Goods?\nthat a UN specification mark is not required on packaging manufactured and or used in\n49 CFR 173.196 outlines the components of authorized packagings and indicates that each\npackagings subject to this section are not subject to the specification marking requirements of\npackage must be capable of passing the tests specified in 178.609. 178.609(i) stipulates that\n178.503. As long as a package met all the requirements in 173.196 and was capable of passing\nthe tests in 178.609, would it require the UN specification mark in order to transport infectious\nsubstances legally in the US?\n2. If a US manufacturer were to put a UN specification mark on such packaging what\nwould it designate?\nstandard is set forth in the HMR and the other in which a UN standard is not set forth. Is the UN\n178.3(b) outlines two options for marking of UN standard packagings: one in which the UN\nstandard set forth in 178.609 or would a manufacturer be required to establish that the packaging\npackaging for infectious substances manufactured in the US, indicate conformance to 178.609 or\ncontorms to the applicable ICAO standards? In other words, does the UN specification mark, on\nconformance to the ICAO standards set out in Packing Instruction 602 and Part 7 Chapter 6 of\nThank you for taking the time to respond at your earliest convenience so that we may plan our\nproduction strategy. Please call me at 1-800-814-7484 if any further clarification is needed.\nSincerely,\nEau look\nBiological Technical Specialist\nEric Cook\nSaf-T-Pak, Inc.\n101, 17872 - 106 Avenue\nEdmonton, Alberta Canada T5S 1V4\n• (403) 486-0211\nFax: (403) 486-0235\n(800) 814-7484\nE-Mail: 75357.1226@compuserve.com\nWebsite: www.saftpak.com\n\n<<<PAGE 4>>>\n\nNAST\n$ 1999\nSAF I PAK\nEdward Mazzul1o\nSuite 101 17872 106 arenue\nUS Department of Transportation\nResearch and Special Programs Admin.\nEdmonton. Alberta Conada\nOffice of Hazardous Materials\nStandards.\nTSS 1Y4\n400 Seventh\nStreet, s.w.,\nwashington, D.C.\n20590","truncated":false,"body_characters":5026}