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.
Sincerely,
Hattie L. Mitchell, Chief
Regulatory Review and Reinvention
Office of Hazardous Materials Standards
Enclosure
178.503
Regulation Sections
Section | Subject |
---|---|
178.503 | Marking of packagings |