Display of Identification Number Marking for Bulk Packagings
Pipeline and Hazardous Materials Safety Administration · Mar 8, 1993 · Reference No. 93-0147
Interprets: 49 CFR § 172.101, 49 CFR § 172.302, 49 CFR § 172.331, 49 CFR § 172.332
Reggie’s quick take
Someone asked whether bulk bags carried inside closed vans or trailers must show identification numbers. The agency says yes. A bulk bag, such as a 2,500 pound poly sack, must display its identification number on two opposite sides, on orange panels or plain white square-on-point markings, under §§ 172.302 and 172.331. If that bag rides in a closed trailer or van, the vehicle must also show the number, under § 172.332.
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 concerning the requirements for display of identification number marking for bulk packagings transported inside of closed transport vehicles. I apologize for the delay in responding and hope that it has not caused any inconvenience.
The display of identification number markings apply to both liquid and solid materials in bulk packagings. A bulk bag (e.g., a 2,500 pound poly sack) must be marked with the identification number specified for the material, on two opposing sides, as prescribed in § 172.302 and § 172.331. The identification number must be displayed on orange panels or plain white square-on-point configurations. If the bulk bag is being transported in a closed trailer or van, the identification number must also be marked on the transport vehicle using orange panels or plain white square-on-point configurations (see § 172.332).
In the Hazardous Materials Regulations (HMR; 49 CFR 171-180) the description "RQ Hazardous substance, solid, n.o.s., ORM-E, NA9188" was removed from § 172.101, Hazardous Materials Table, and replaced with "RQ Environmentally hazardous substance, solid, n.o.s., 9, UN3077, III."
I hope this information has been helpful. If you have further questions, do not hesitate to contact us.
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.