You are here

Interpretation Response #06-0118

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

Interpretation Response Details

Response Publish Date: 05-30-2006
Company Name: Manager, Technical Services - Aerosol    Individual Name: Mr. Matthew D. Kuehn 
Country: US

View the Interpretation Document

Response text:

May 30, 2006


Mr. Matthew D. Kuehn                Reference No. 06-0118
Manager, Technical Services - Aerosol
BWAY Corporation
3400 North Powell Avenue
Franklin Park, IL 60131

Dear Mr. Kuehn:

This is in response to your May 8, 2006 letter requesting clarification regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to the marking of cylinders. Your scenario is based on the marking of specification 2P and 2Q aerosol containers. Specifically, you ask if these containers may be marked with your company name “Bway.”

The answer is yes. Sections 178.33-9(a)(2) and 178.33a-9(a)(2) for specification 2P and
2Q aerosol containers, respectively, state that either the name or symbol of the
manufacturer must be marked on the container. Therefore, it is acceptable to mark your
2P and 2Q containers with “Bway” to comply with § 178.33-9(a)(2) and 178.33a-9(a)(2).

I hope this information is helpful.



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

178.33-9 (a)(2), 173.33a-9 (a)(2)

Regulation Sections

Section Subject
§ 178.33-9 Marking