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Interpretation Response #00-0144 ([Midwest Rubber Mfg., Inc.] [Ms. Darlene Rank])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: Midwest Rubber Mfg., Inc.

Individual Name: Ms. Darlene Rank

Location State: WI Country: US

View the Interpretation Document

Response text:

June 5, 2000

Ms. Darlene Rank               Ref. No. 00-0144

Midwest Rubber Mfg., Inc.

P. 0. Box 207

250 Industrial Circle

Stoughton, WI 53589

Dear Ms. Rank:

This is in response to your letter dated May 5, 2000 requesting verification on the proper shipping of Adhesives, 3, UN 1133, PG II.  You ask if it is possible to ship 8 oz. cans in a case of 24, weighing 13 lbs. per case, without labeling the cans.  You further state that the case would be palletized and shrink-wrapped.

The labeling requirements found in 49 CFR 172.400 require each non-bulk package (i.e., case) to be labeled with the label specified in the §172.101 Table for the material.  In your situation, the hazard warning labels are only required on the outside package and are not required to be placed on inner packages (i.e., cans).  If several cases are shrink-wrapped, and the labels on the packages are not visible, the label and other markings must be placed on the shrink-wrapped film. overpack.  See §173.25.

I hope this information is helpful.

Sincerely,

Hattie L. Mitchell

Chief, Regulatory Review and Reinvention

Office of Hazardous Materials Standards

 

172.400

Regulation Sections