Interpretation Response #02-0083 ([BOC Gases] [Jack B. Wer])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: BOC Gases
Individual Name: Jack B. Wer
Location State: NJ Country: US
View the Interpretation Document
Response text:
APR 29, 2002
Mr. Jack B. Wert Ref No.: 02-0083
BOC Gases
575 Mountain Avenue
Murray Hill, NJ 07974
Dear Mr. Wert:
This is in response to your letter dated March 12; 2002 requesting clarification on § 172. 400a(a) (1) of the Hazardous Materials Regulations (HMR-49 CFR 171 -180) regarding the use of a cylinder identification collar in lieu of a cylinder label, For our review, you provided a sample of your company's cylinder identification, collar, affixed tq.Ole to , part of a ^cylinden
As provided by § 172.400a (a)(1), cylinders containing flammable (Division 2.1) and nonflammable (Division 2.2) compressed gases that are carried by private or contract motor carrier and which are not overpacked are authorized to be marked in accordance with CGA Pamphlet C-7, appendix A without further DOT labeling.
As set forth in CGA Pamphlet C-7, appendix A, A-7, shoulder markings are permissible as long as the basic markings do not cover any permanent markings. The cylinder identification collar you provided rovers the permanent DOT specification markings. Therefore, the cylinder identification collar does not meet the conditions set forth in CGA Pamphlet C-7, appendix A. However, except for your identification collar covering the permanent markings on the DOT specification cylinder, the sample collar otherwise conforms to the provisions specified in § 172.400a (a)(1).
I trust this satisfies your inquiry. If we can be of ^Ruther assistance, please contact us.
Sincerely,
Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards
Regulation Sections
| Section | Subject |
|---|---|
| 172.400 | General labeling requirements |