Interpretation Response #01-0256 ([Haarmann & Reimer] [Mr. Richard A. Winter])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Haarmann & Reimer
Individual Name: Mr. Richard A. Winter
Location State: NJ Country: US
View the Interpretation Document
Response text:
January 4, 2002
Mr. Richard A. Winter Reference No. 01-0256
Director of Logistics
Haarmann & Reimer
180 Industrial Parkway
Branchburg, NJ 08876
Dear Mr. Winter:
This responds to your letter dated October 3, 2001, regarding the specification marking requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you inquire whether inverted (upside down) UN standard markings permanently embossed on plastic drums would be a violation of
§ 178.3(a)(3). You state that your supp-lier has since corrected the error but you want to use the existing drums
if they are considered conforming to the HMR.
The method of marking you describe in your letter is not recommended; however, if the inverted UN standard marking meets the requirements otherwise prescribed in § 178.3, this method would not be considered a violation of the HMR.
Sincerely,
John Gale
Transportation Regulatory Specialist
office of Hazardous Materials Standards
178.3(a)(3)