Question: We are an international shipper of hazardous materials by all modes so harmonization is a key concern. Under the HMR Subpart D, general marking requirements for Bulk Packagings, the UN identification number is mentioned, but the proper shipping name is not a general requirement. However, under IMDG provisions both the PSN and UN ID#s are required marks for bulk and non-bulk packagings. Are there plans to harmonize marking requirements in the HMR consistent with international regulations? ANSWER: When the HMR was harmonized with the international regulations through HM-181 in the early 1990s, the effort was not so much an effort to "throw out the old and bring in the new" as it was to "adapt the old to accommodate the new." The terms "non- bulk packaging" and "bulk packaging" are vestiges from the old HMR predating international harmonization. These terms are not used in the international regulations even though some attempts were made to introduce the terms in the international regulations as well. They were used extensively in the earlier HMR regulations and, with HM-181 international harmonization already a monumental task, little thought was given to eliminating these terms. As such they remain and the terms continue to be used in the HMR to differentiate between the marking requirements for non-bulk and bulk packagings.
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