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DOT Commits To Clarifying Approval Of Stenciled UN Marking

January 10th, 2006 by Howard Skolnik

Filed under: DOT/UN

With all the heated issues emanating from the office of the US DOT, there has been a non-critical technical issue under consideration that could have disqualified stencils as an approved UN marking method in accordance with CFR 178.503(11)(e). In 2002, Sandia National Labs asked DOT for approval on a UN mark in which, due to stenciling, the circle around the “un” had four breaks in the line. To this, DOT responded that breaks in the circle were not authorized – though they did not comment about the other stenciled letters in the mark, which also had broken line lettering. While we believe that DOT had no intention of ever citing the broken line circle as non-compliant, the effect of this interpretation has caused government agencies (DOD, DOE) to require stenciled marks to be re-marked with varying methods to complete the breaks around the UN letters (but not the remainder of the mark). After 3 years of petitioning DOT to rescind their interpretation to Sandia, on October 11, 2005, DOT stated that “a stencil with the minimum gap necessary to support the center of the circle with the letters “u” and “n” (both lower case) is authorized to apply the symbol to the packaging. We (DOT) intend to clarify this issue in future rulemaking.” Though a specific ratio of line to gap has not yet been specified, we believe that a ratio of 90% line to 10% total gap will be compliant with the “minimum” statement.

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