Marking Requirements for DOT Type 7A and Nuclear Regulatory Commission (NRC) Type 7B Packagings
Pipeline and Hazardous Materials Safety Administration · Sep 10, 2001 · Reference No. 01-0153
Interprets: 49 CFR § 172.302
Reggie’s quick take
Someone asked whether DOE sites must add the bulk package markings in § 172.302 to Type A (DOT 7A) or DOE or NRC certified Type B packages of radioactive material that are already marked under §§ 172.301 and 172.310. The agency's answer is that these packages are treated as non-bulk packagings, so they need the proper shipping name and identification number under § 172.301. The agency would also accept a package marked as a bulk package.
Written by AI (Claude) on Oct 22, 2026. Robots make mistakes and leave things out, so the letter below is what counts. Not legal advice.
This is in response to your June 14, 2001, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) regarding the marking requirements for shipments of DOT 7A Type A specification packaging and to Department of Energy (DOE) or Nuclear Regulatory Commission (NRC) certified Type B packagings used to transport radioactive materials and wastes. Specifically, you ask whether DOE sites must apply the general bulk package markings required by 49 CFR 172.302 (i.e. identification numbers on orange panels or placards, etc.) to Type A or Type B packages of radioactive material when these packages: (a) are marked to meet 49 CFR 172.301, 172.310 and other relevant sections of Subpart D.
The marking and labeling requirements for these packages depend on whether they are construed to be bulk or non-bulk packagings. Currently, the HMR is silent in regards to how these packages are defined. It has been this office position to define these packages as meeting the definition of a non-bulk packaging. Accordingly, § 172.301 states that a non-bulk packaging containing a hazardous material shall be marked with the proper shipping name and the identification number. However, we would accept a package marked as prescribed for a bulk package.
A letter of interpretation applies the regulations to the facts the requester described. It isn’t a regulation and isn’t legal advice. The agency’s copy.