Marking Requirements for Bulk Packages
Pipeline and Hazardous Materials Safety Administration · Aug 27, 2001 · Reference No. 01-0179
Interprets: 49 CFR § 172.203(k)
Reggie’s quick take
The letter answers a question from someone (not named) about bulk packages holding a hazardous material covered by § 172.203(k). They asked whether such a package must carry the technical name required for non-bulk packages under § 172.301(b). PHMSA says no: the HMR does not require a technical name marking on a bulk package holding that material.
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 letter dated July 11, 2001, requesting clarification of marking requirements for bulk packages in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if a bulk package containing a hazardous material subject to § 172.203(k) must be marked with the technical name as specified in § 172.301(b) for a non-bulk package.
The answer is no. There is no requirement in the HMR to mark a technical name on a bulk package containing a hazardous material subject to § 172.203(k).
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.