Interpretation Response #04-0102 ([Brenntag Stinnes Logistics] [Mr. A. B. Eargood])

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

Interpretation Response Details

Response Publish Date: 06/16/2004

Company Name: Brenntag Stinnes Logistics

Individual Name: Mr. A. B. Eargood

Location State: KY Country: US

View the Interpretation Document

Response text:

Jun 16, 2004

Mr. A. B. Eargood                Reference No. 04-0102
Brenntag Stinnes Logistics
P. 0. Box 20
Henderson, KY 42420

Dear Mr. Eargood:

This is in response to your letter concerning the labeling requirements under the
Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether the labels required by § 172.406 on DOT 106 or 110 multi-unit tank car tanks
may be stenciled on each end of the tank car tank. In a conversation with a member of my staff, you stated that the cylinders for the chlorine and sulfur dioxide are painted gray and light green respectively. You propose to paint the ends of the cylinders white and stencil the labels in the white area.

The answer is yes provided the stenciled labels fully conform to all requirements for durability, design, size and color specified in § 172.407, 172.416, and 172.442.

I trust this satisfies your request.

Sincerely,

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

172.406

Regulation Sections