The United States Department of Transportation’s (USDOT) Pipeline and Hazardous Materials Safety Agency (PHMSA) has made public a recent Letter of Interpretation which further clarifies the issue of required marking size when applying the Limited Quantity Marking for ground transport in the United States. This is the marking referenced:
In the letter, dated February 27th, 2014 and directed to SC Johnson and Sons, Inc. in Racine, Wisconsin, PHMSA specifically states that the only valid reason acceptable to them for reducing the size of the marking from the 100mm x 100mm dimensions specified in US 49 CFR 172.315(a)(2) is IF the physical size of the package itself precludes application of the full-size marking (i.e., it will not fit on one side of the package without “spilling over” onto an adjacent side). SC Johnson had noted to PHMSA that numerous other printed and applied markings on their product packages made application of the full size marking difficult. PHMSA essentially vetoed that issue as a reason to apply a smaller marking, and reiterated that only package size and not the presence of other applied markings is a valid reason for reduction. SC Johnson had proposed the application of an 80mm x 80mm marking instead, to avoid interfering with other markings. PHMSA also specifically noted that if a reduction in size of the marking is made for the package size reason above, that the minimum marking size acceptable is 50mm x 50mm.
The Council on the Safe Transportation of Hazardous Articles, or COSTHA, offers a helpful link to the full Letter of Interpretation, here:
COSTHA is a not-for-profit industry group that offers a network of information and assistance resources to companies concerned in many aspects of transporting hazardous materials, as well as the support industries serving that need. To learn more about COSTHA, see their home site at www.costha.org.
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