Interpretation Response #04-0130 ([CROWN Packaging Technology] [Mr. Lee Robertson])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: CROWN Packaging Technology
Individual Name: Mr. Lee Robertson
Location State: IL Country: US
View the Interpretation Document
Response text:
Oct 12, 2004
Mr. Lee Robertson Reference No. 04-0130
Advisory Scientist
CROWN Packaging Technology
11535 S. Central Avenue
Alsip, IL 60803-2599
Dear Mr. Robertson:
This responds to your letter requesting clarification of the specification marking requirements for DOT specification 2P and 2Q containers in § § 178.33-9 and 178. 33a-9, respectively, of the Hazardous Materials Regulations (HMR; 49 CFR parts 17 1-180). Specifically, you ask if the markings may be affixed by visible ink jet printing on the container body and then covered by a plastic label. At our request, you also submitted two marked sample containers. In a recent telephone conversation with a member of my staff, you also asked if the specification marking may be printed on the removable product label covering the containers.
In accordance with § 178.3(a), a packaging represented as manufactured to a DOT or UN standard must be marked on an unobstructed area of a non-removable component of the packaging. Sections 178.33-9 and 178.33a-9 authorize printing the specification marking on the container as one of the methods for marking the 2P and 2Q containers. Printing the specification marking on a label affixed to the container with strong adhesion would satisfy this requirement. Additionally, as required by § 178.3(f), the markings must be accessible (not covered), permanent, contrasting, and legible. Markings made by jet printing are acceptable, if they meet the requirements. However, it is our opinion that the markings on your container, made by a series of dots, are not readily legible.
I trust this satisfies your inquiry.
Sincerely,
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
178.33a9