Billing Code - PHMSA - Department of Transportation

mark packages in a format that makes it difficult for first responders to identify the
commodity associated with a particular package.
In response to the NPRM, PHMSA received several comments concerning this
proposed requirement. DGAC and Dow suggested extending the compliance date for this
provision to January 1, 2017 to allow companies time to make the transition, and for the
depletion of both finished product and prepackaged inventory that do not meet the
requirements of the proposal.
Veolia noted that their company’s propriety software produces markings that would
not be in compliance with the proposed size limitations and that they would incur a cost to
reprogram their system if the proposal is maintained. They further contended that in 20
years of displaying the marking they are unaware of any instances of the markings being
questioned as being too small or illegible. Veolia requested that the minimum size
requirement apply to international shipments only.
Stericycle and the HWI requested an exception to this marking requirement for
dedicated carriers of regulated medical waste. These commenters stated that the proposed
change would impose a significant cost on the industry. They requested an exception for
the continued use of existing containers used to transport regulated medical waste and
permanently marked with the applicable “UN” number.
PHMSA accepts that many packages are currently marked in a manner that may not
in all cases meet the new minimum size standards. In response to the comments raised to
the NPRM we will provide, for domestic transportation, a transition period to continue
using non-bulk packagings displaying “UN” or “NA” number markings in accordance with
the requirements in effect on October 1, 2011 (i.e., no minimum size), until January 1,
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