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Interpretation Response #04-0261 ([Dangerous Goods Advisory] [Mr. Alan I. Roberts])

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

Interpretation Response Details

Response Publish Date:

Company Name: Dangerous Goods Advisory

Individual Name: Mr. Alan I. Roberts

Location State: DC Country: US

View the Interpretation Document

Response text:

Oct 11, 2005

 

Mr. Alan I. Roberts                Reference No. 04-0261
President
Dangerous Goods Advisory’
1100 H Street NW, Suite 740
Washington, DC 20005-5484

Dear Mr. Roberts:

This is in response to your November 8, 2004 Letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Please accept my apology for our delay in responding and any inconvenience this may have caused. Specifically you ask this office to reconsider its previous interpretation regarding submitted examples of stenciled United Nations (UN) symbol markings (Ref. No.: 02-0265).

The markings as shown in the examples from the letter from Mr. Roland M. Kelley of Sandia National Laboratories do not conform to the requirements in § 178.503. However, a stencil with the minimum gap necessary to support the center of the circle with the letters “u” and “n” is authorized to apply the UN symbol to the packaging. We intend to clarify this issue in a future rulemaking.
I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.
Sincerely,

 

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

Cc: Mr. Roland M. Kelley, Sandia National Laboratories, P.O. Box 5800 MS 1120, Albuquerque, NM 87185

178.503

Regulation Sections

Section Subject
178.503 Marking of packagings