Are ORM-D Markings Allowed to Continue Beyond December 31,2020?

摘要

In a January 12, 2021 request for a letter of interpretation from PHMSA (the letter follows this report), an inventory manager indicates his company has thousands of boxes in inventory that are marked with both the diamond Limited Quantity mark and with Consumer Commodity and ORM-D markings. He is aware of a DOT notification bulletin (see ORM-D Phase-out Poster, below) concerning the ORM-D phase-out ending on December 31, 2020 and asks if these dual-marked packagings can be shipped "as is without the time-consuming effort to cover up the ORM-D markings" and, if so, will carriers accept these shipments. He expresses concern that it is extremely labor intensive to cover up the phased-out markings.