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Interpretation Response #06-0136 ([Samax Enterprises] [Mr. Perry J. Patton])

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

Interpretation Response Details

Response Publish Date:

Company Name: Samax Enterprises

Individual Name: Mr. Perry J. Patton

Location State: NY Country: US

View the Interpretation Document

Response text:

Jul 11, 2006


Mr. Perry J. Patton                 Reference No. 06-0136
Samax Enterprises
154 Eastwood Blvd.
Centereach, NY 11720

Dear Mr. Patton:

This is in response to your May 26, 2006 letter regarding the marking and labeling requirements of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You include a flammable liquid hazard label, an inhalation hazard label, and an orientation arrow marking in your letter. You also provide a Material Safety Data Sheet (MSDS) for the “Liquid No Wash” product. Specifically, you ask if the labels and orientation markings included in your letter are required to be displayed on a 5-gallon container of the product.

Under § 173.22, it is the shipper’s responsibility to properly class and describe a hazardous material. Marking and labeling requirements are based on the proper shipping description of the hazardous material. The MSDS sheet for your product indicates the proper shipping description for “Liquid No Wash” is “Paint related material, 3, UN1263, PG II.” For a material described as such, the “Flammable liquid” label specified in § 172 19 and included in your letter must be displayed on the outer surface of the package. An inhalation hazard label may not be displayed on a package containing “Liquid No Wash” because the material does not meet the definition of a poison inhalation hazard. Orientation arrow markings must be displayed on two opposite vertical sides of a combination package having inner packagings containing liquid hazardous materials. Although not required by the HMR, orientation arrows may be displayed on the surface of a single package (e.g., a 5-gallon container or inner packaging.

I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.



John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards

172.419, 173.22

Regulation Sections

Section Subject
172.419 FLAMMABLE LIQUID label
173.22 Shipper's responsibility