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Interpretation Response #06-0224 ([Rohm and Haas Company] [Ms. Carrie Wayne])

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

Interpretation Response Details

Response Publish Date:

Company Name: Rohm and Haas Company

Individual Name: Ms. Carrie Wayne

Location State: PA Country: US

View the Interpretation Document

Response text:

Nov 28, 2006


Ms. Carrie Wayne                 Reference No. 06-0224
NAR Logistics Safety Manager
Rohm and Haas Company
100 Independence Mall West
Philadelphia, Pennsylvania 19106

Dear Ms. Wayne:

This responds to your October 6, 2006 letter requesting clarification on marking
requirements under § 172.313(b) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if it is permissible to mark a non-bulk packaging
used to transport Division 6.1 materials with the word “Toxic” instead of “Poison.”

The HMR permit the use of either the word “Poison” or “Toxic” on shipping papers (see § 172.203) and labels (see § 172.430). Moreover, the HMR permit the word “toxic” to be used interchangeably with the words “poison” or “poisonous” in shipping descriptions
and proper shipping names (see § 172.101(c)(3)). It was our intention to permit the same flexibility for package markings. Therefore, you may use the word “Toxic” instead of
“Poison” when marking an outer packaging used for Division 6.1 materials.

I hope this answers your inquiry.



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

172.101(c)(3), 172.203, 172.313(b)

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table
172.203 Additional description requirements
172.313 Poisonous hazardous materials