Interpretation Response #07-0038

Interpretation Response Details

Mar 13, 2007

Mr. Jim Hara                 Reference No. 07-0038
Lockheed Martin Missiles and Space Company
1111 Lockheed Martin Way
Sunnyvale, CA 94086

Dear Mr. Hara:

This is in response to your February 14, 2007 letter regarding the marking of plywood boxes. You asked whether a tape covered paper label may be used to mark the UN certification on the plywood box under § 178.3 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).

The marking requirements under § 178.3(a)(3) state that “markings must be stamped, embossed, burned, printed or otherwise marked on the packaging to provide adequate accessibility, permanency, contrast, and legibility so as to be readily apparent and understood.” The specific sizes for letters and numerals must be as required in § 178.3(a)(4). Use of a tape covered paper label is authorized to mark the UN certification on plywood boxes provided the offeror can assure that the above requirements are met.

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

Sincerely,

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

178.3 (a)(3), 173.476

Regulation Sections