ICC's Regulatory Helpdesk
Regulatory Helpdesk: April 23

Using absorbents with variation packaging, UN marking height, limited quantity, and de minimis quantities

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. We’re here to help you become independent with – and understand the whys and hows – of the regulations.

Absorbent Materials in Variation Packaging

Q. Can I use absorbent padding instead of the vermiculite as the absorbent in a 4GV package that was tested with vermiculite?
A. Per the 49 CFR §178.601, the packaging must meet the standard to which it is certified and the material must be of the same type or design as used in the tested design type, in this case vermiculite. Therefore vermiculite would have to be used to comply with the regulations.

UN Number Height

Q. Is there a minimum size requirement for the UN number on a lithium battery mark?
A. The only place that a specific size requirement is referenced regarding the UN number on a lithium battery mark is in the IATA DGR – §7.1.5.5.2(b)- which states that the UN number “should be” at least 12 mm high.

None of the other common (49 CFR §173.185(c)(3)(i); IMDG §5.2.1.10; TDG §4.24; or UN Model §5.2.1.9) regulations quote a minimum UN number size specifically for the lithium battery mark. All of the regulations referenced allow for proportional reduction, of features without specified dimensions, when the authorized Continue Reading…