Billing Code - PHMSA - Department of Transportation

2017.
PHMSA maintains that there is benefit to harmonization in this case, and having a
single standard outweighs the cost incurred by a company to revise its software and
systems to produce compliant markings. The transition period for the continued use of the
current markings in domestic transportation provides an opportunity for companies to
revise their marking systems and maintain compliance. PHMSA is sympathetic to the
assertion that the containers used to transport regulated medical waste are often
permanently stamped with the “UN” number and the containers often have very long
useful lives. Therefore PHMSA is also including an exception that allows packages that
are permanently marked with the UN number (e.g., by embossing or through a heat stamp
process) and are manufactured prior to January 1, 2017 to continue in service for the life of
the container.
DGAC noted that while an inch conversion was provided in the preamble there is
no inch conversion noted in the regulations text. This was an oversight and has been
corrected in this final rule.
COSTHA questioned if the minimum size of the “UN” number markings should be
dictated by the maximum capacity of the outer package or the inner packagings. COSTHA
proposed an example package consisting of 2 inner packagings of 4 L each. Maximum
capacity is defined in § 171.8 as “the maximum inner volume of receptacles or
packagings.” A package containing 2 inner packagings with a maximum capacity of 4 L
each would have a maximum capacity of 8 L, and thus would require a 6 mm minimum
UN number marking.
It was also noted that the UNSCOE, at its 39 th session, provided an exception from
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