Interpretation Response #04-0252 ([C.L. Smith Company] [Mr. Lonnie Jaycox ])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: C.L. Smith Company
Individual Name: Mr. Lonnie Jaycox
Location State: AL Country: US
View the Interpretation Document
Response text:
Nov 9, 2004
Mr. Lonnie Jaycox Reference No. 04-0252
C.L. Smith Company
1311 South 9th Street
St. Louis, MO 63110-2535
Dear Mr. Jaycox:
This is in response to your November 3, 2004 letter concerning prohibitive marking under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically you ask if the logo depicted below is prohibited under the provisions of § 172.312(b).
The answer is no. Section 172.312(b) prohibits the use of arrows for purposes other than indicating proper package orientation on packages containing liquid hazardous materials. It is our opinion that the "Transit Tested" logo depicted is sufficiently distinct from any orientation marking referenced by the HMR.
I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.
Sincerely,
Hattie L. Mitchell
Regulatory Review and Reinvention
Office of Hazardous Materials Standards
172.303, 172.312(b)