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Q&A: Does the new identification number package mark height requirement apply to hazardous waste lab packs?

Q&A: Does the new identification number package mark height requirement apply to hazardous waste lab packs?

A question from the regulated community (01.26.17):

Hello,
Do the new labeling requirements impact lab packs?
Are they considered ‘non-bulk’ and thus must conform to the new UN size?
Thanks,Hazardous waste lab pack drums

My reply, buying time:

That’s a good question! Let me research and get back to you.

Final answer that same day:

I believe I have an answer to your question.  I assume it is related to the new size requirement for the identification number on a non-bulk packaging.  Please see below:

  • The new size requirement for the identification number applies to the marking on a non-bulk packaging.
  • Though possible, it is unlikely that a lab pack for hazardous waste will be shipped in anything other than a non-bulk packaging.
  • There is no exception to the new size requirement for lab packs that I can find in 49 CFR 173.12.
Therefore, if a lab pack of hazardous waste meets the definition of a hazardous material (the hazardous waste from a CESQG does not) then it must be shipped according to the regulations of the USDOT.  Since January 1, 2017, those regulations have mandated the minimum height of the identification number marking (just the identification number, nothing else) on a non-bulk packaging.
I hope this helps.
Please don’t hesitate to contact me with any other questions.