PHMSA letter of interpretation

Location of the Required Markings and Label

Pipeline and Hazardous Materials Safety Administration · Jun 28, 1995 · Reference No. 95-0147

PHMSA says to use caution with this letter.

Interprets: 49 CFR § 172.406

This is in response to your letter dated May 18, 1995 requesting clarification on the proper location of the required markings and label on a fiberboard box containing liquid hazardous materials.

Section 172.406 requires the label to be located on the same surface of the package near the proper shipping name marking, if the package dimensions are adequate. However, if the package dimensions will not allow this, the proper shipping name marking and label may be put near each other on two adjoining sides of the package.

Non-bulk combination packages having inner packagings containing liquid hazardous materials must be marked with package orientation markings on two opposite vertical sides of the package with the arrows pointing in the correct upright direction.

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.