Interpretation Response #05-0103 ([Office of Hazardous Materials Enforcement (PHH-46)] [Mr. William Stevens Sr.])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Office of Hazardous Materials Enforcement (PHH-46)
Individual Name: Mr. William Stevens Sr.
Location State: GA Country: US
View the Interpretation Document
Response text:
APR 26, 2005
Mr. William Stevens Sr. Ref. No. 05-0103
Hazardous Materials Enforcement Specialist
Office of Hazardous Materials Enforcement (PHH-46)
233 Peachtree Street, NE, Suite 602
Atlanta, GA 30303
Dear Mr. Stevens:
This is in response to your April 21, 2005 letter concerning the UN specification packaging marking requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your questions are paraphrased and answered as follows:
QI. Maya manufacturer use the unregistered symbol "US" as its symbol on 2P and 2Q packagings to satisfy the requirements in §§ I78.33-9(a)(2) and 178.33-9a(a)(2)?
AI. The answer is no. The manufacturer must use its complete name and address or a registered symbol. The manufacturer may request a symbol (i.e., an "M" number) from DOT; however, it may not register "US" as a symbol. The M number is marked on the packaging in lieu of the manufacturer's name and address. "US" or "US Can" may then be marked on the packaging after the M number, if desired. Requests for a symbol may be submitted to the Office of Hazardous Materials Exemptions and Approvals, PHH-30, Attention: Linda Cooper, Pipeline and Hazardous Materials Safety Administration, 400 7th Street, S.W., Washington, DC 20590-0001 or telefax 202-366-3753.
Q2. Maya manufacturer use "invisible ink" (i.e., ink that is only visible when viewed
under an ultraviolet light) to apply specification markings?
A2. No. Specification markings required under the HMR must be visible without the use of specialized equipment.
I hope this satisfies your request.
Sincerely,
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards
178.3 (a)(1)