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Billing Code - PHMSA - Department of Transportation

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minimum marking size requirements for cylinders <strong>of</strong> 60 liters water capacity or less.<br />

<strong>PHMSA</strong> agrees that cylinder markings have historically been allowed provisions that<br />

would allow for smaller UN number markings than other non-bulk packages and is<br />

providing an exception for cylinders <strong>of</strong> 60 liters water capacity or less consistent with the<br />

recent UNSCOE exception.<br />

Therefore, with the aforementioned transition period, exceptions, and note,<br />

<strong>PHMSA</strong> is specifying a marking size consistent with package marking sizes adopted in the<br />

17th Revised Edition <strong>of</strong> the UN Model Regulations.<br />

Section 172.312<br />

Section 172.312 details the specific marking requirements for liquid hazardous<br />

materials in non-bulk packagings. Paragraph (a) <strong>of</strong> this section describes scenarios when<br />

package orientation arrows must be displayed on the outside <strong>of</strong> a package. Provided<br />

certain criteria are met, paragraph (c) excepts certain shipments from the requirements <strong>of</strong><br />

paragraph (a) and thus, the requirement to display the package orientation arrows on the<br />

package. Currently § 173.312(c)(3) states that when <strong>of</strong>fered or intended for transportation<br />

by aircraft, packages containing flammable liquids in inner packagings <strong>of</strong> 120 mL (4 fluid<br />

oz.) or less prepared in accordance with § 173.150 (b) or (c) <strong>of</strong> this subchapter when<br />

packed with sufficient absorption material between the inner and outer packagings to<br />

completely absorb the liquid contents are not required to display the package orientation<br />

arrows on the outside <strong>of</strong> the package. The ICAO TI have been amended to extend this<br />

exception to the package orientation markings to all liquid hazardous materials in inner<br />

packagings <strong>of</strong> 120 mL (4 fluid oz.) when packed with sufficient absorption material<br />

between the inner and outer packagings to completely absorb the liquid contents. <strong>PHMSA</strong><br />

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