Interpretation Response #00-0139 ([U. S. Department of Transportation] [Mr. Kent D. Fleming])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: U. S. Department of Transportation
Individual Name: Mr. Kent D. Fleming
Location State: IA Country: US
View the Interpretation Document
Response text:
May 18, 2000
Mr. Kent D. Fleming Ref. No. 00-0139
Federal Motor Carrier Safety Administration
U. S. Department of Transportation
105 Sixth Street
Ames, Iowa 50010-6337
Dear Mr. Fleming:
This is in response to your letter dated April 20, 2000, requesting clarification of the requirements for the display of a hazard warning label on a non-spillable wet battery. As shown in your enclosed photographs, the battery displays a reduced size CORROSIVE label, approximately 1.5 inches on each side. You asked if the reduced size label is in compliance with the provisions of §172.407(c), especially taking into account the exception from regulations, including labeling, provided for batteries in §173.159(d).
The reduced size label on the battery as shown in the photographs does not comply with the requirements in §172.407(c). Even though §173.159(d) provides a complete exception from the HMR under specified conditions, if the shipper attempts to comply with a portion of the HMR they must do so in compliance with that specific requirement. Since the shipper labeled the battery, the label must comply with the specifications in §172.407(c), which states that a hazard warning label must be at least 100 min (3.9 inches) on each side.
I hope this information is helpful.
Sincerely,
Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards
172.407
Regulation Sections
| Section | Subject |
|---|---|
| 172.407 | Label specifications |