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Interpretation Response #06-0166 ([American Pyrotechnics Association] [Mr. Gregg Smith ])

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

Interpretation Response Details

Response Publish Date:

Company Name: American Pyrotechnics Association

Individual Name: Mr. Gregg Smith 

Location State: MD Country: US

View the Interpretation Document

Response text:

Oct 10, 2006

 

Mr. Gregg Smith                 Reference No. 06-0166
Safety Program Manager
American Pyrotechnics Association
7910 Woodmont Avenue, Suite 1220
P.O. Box 30438
Bethesda, MD 20814

Dear Mr. Smith:

This responds to your email sent to Mr. Robert Lynch in the Office of Hazardous Materials Enforcement concerning marking requirements for packages containing Fireworks, UN0336, 1.4G, under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your inquiry has been forwarded to this office for a response.

Specifically, you indicate that the name “Consumer Fireworks” is routinely marked on packages of fireworks. You enclosed a photograph showing a typical marking and ask if this marking is acceptable under the marking requirements of the HMR. The answer is no. The HMR specify that the proper shipping name and identification number marked on a package must be as shown in the § 172.101 Hazardous Materials Table (see § 172.301(a) (1)) and must be located away from any other marking that could reduce its effectiveness (see § 172.304 (a) (4)). The marking displayed on the package in the photograph does not satisfy these requirements. “Consumer Fireworks” is not a proper shipping name shown in the § 172.101 Hazardous Materials Table. Further, the additional wording “Consumer” may reduce the clarity of the required marking.

It is our recommendation that if your members want to continue using the name “Consumer Fireworks” as a package marking for purposes other than compliance with the HMR, the marking should be located away from the proper shipping name and identification number markings.

I trust this satisfies your inquiry. Please contact us if we can be of further assistance.

Sincerely,

 

Edward T. Mazzullo
Director
Office of Hazardous Materials Standards

172.101, 173.62

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table
173.62 Specific packaging requirements for explosives