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Interpretation Response #02-0166 ([AFGO Laboratories, Inc.] [Dale D. Benincasa])

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

Interpretation Response Details

Response Publish Date:

Company Name: AFGO Laboratories, Inc.

Individual Name: Dale D. Benincasa

Location State: CO Country: US

View the Interpretation Document

Response text:

Jul 24, 2002

Ms. Dale D. Benincasa                     Reference No. 02-0166
President
AFGO Laboratories, Inc.
P.O. Box 390413
Denver, CO 80239

Dear Ms. Benincasa:

This is in response to your June 13, 2002, letter concerning the manner in which proper shipping name and identification number markings may be displayed on your product label under the Hazardous Materials Regulations (HMR; 40 CFR Parts 171-180).

Section 172.304(a)(4) states that the required markings (proper shipping name and identification number) must be located away from any other marking (such as advertising) that could substantially reduce its effectiveness.  The required markings appearing on your enclosed label satisfy this requirement.

If you wish to make the required marking more prominent, the label could be modified by placing the required markings (proper shipping name and identification number) on the upper left side of the label where the product directions are displayed and the product direction could be place directly under the required markings.  In our opinion, modifying your product label in this manner would satisfy the requirement (§172.304) to locate the package marking away from other mark

I hope this information is helpful.  Please contact us if you require additional assistance.

Sincerely,

Delmer F. Billings
Chief, Standards Division
Office of Hazardous  Materials Standards

172.304(a)(4)

Regulation Sections

Section Subject
172.304 Marking requirements