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Interpretation Response #03-0046 ([Specialty Industries] [Mr. Marc Caron])

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

Interpretation Response Details

Response Publish Date:

Company Name: Specialty Industries

Individual Name: Mr. Marc Caron

Location State: PA Country: US

View the Interpretation Document

Response text:

Feb 28, 2003


Mr. Marc Caron                Reference No. 03-0046
Packaging/Sales Engineer
Specialty Industries
175 East Walnut St.
Red Lion, PA 17356

Dear Mr. Caron:

This is in response to your letter concerning the placement of UN markings displayed on a 4G fiberboard box under § 178.503 of the Hazardous Materials Regulations (49 CFR Parts 171-180).  Specifically, you ask whether the placement of the markings, applied in a single line but with the year of manufacture offsetted and placed to the right of the other markings, is acceptable.  Additionally, you ask if the markings are not acceptable could a custom label bearing the required markings in a single line as illustrated in be used to cover the incorrect markings.  You enclosed a photograph of the marked packaging for our review.

Your packaging markings, as represented on the photograph, does not satisfy the marking requirements in § 178.503 as placement of the year of manufacturer is confusing and is not readily associated with the other markings.  You may use a custom label bearing the required markings as you suggest, or cover or obliterate the printed year of manufacture and re-mark the year of manufacture next to and in alignment with the other markings as shown in § 178.503(e)(2).

I hope this satisfies your request.



Hattie L. Mitchell, Chief
Regulatory Review and Reinvention
Office of Hazardous Materials Standards



Regulation Sections

Section Subject
178.503 Marking of packagings