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Interpretation Response #07-0146

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

Interpretation Response Details

Response Publish Date: 08-30-2007
Individual Name: Mr. Frank Milam
Location state: NJ    Country: US

View the Interpretation Document

Response text:

Aug 30, 2007

Mr. Frank Milam                              Reference No. 07-0146
1900 River Road
Burlington, NJ 08016

Dear Mr. Milam:

This is in response to your July 19, 2007 letter and your follow-up letter of July 23, 2007, requesting that this Office review your company"s hazard warning labels for compliance with the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You enclosed approximately 32 different labels and duplicates of those labels in a follow-up letter, sixty- four (64) in all.

Under the HMR, hazard warning labels must conform to the requirements specified in § 172.407. Any color on a hazard warning label, upon visual examination, must fall within the color tolerances on the appropriate color charts conforming to the technical specifications set forth in Table 1 or 2 in Appendix A to Part 172 (see § 172.407(d)(4)). In accordance with § 172.407(d)(5), labels conforming to PANTONE® color standards are also acceptable. However, if you choose to use PANTONE® colors, the labels must be an exact match to the color in the PANTONE® formula guide coated/uncoated.

Labels are required to be at least 100 mm (3.9 inches) on each side with each side having a solid line inner border 5.0 to 6.3 mm (0.2 to 0.25 inches) from the edge (see
§ 172.407(c)). The background color on each label must be as prescribed in § 172.411 through 172.448 (see § 172.407(d)(1)). The symbol, text, numbers, and border must be shown in black on a label, except that white may be used on a label with a one color background of green, red, or blue, and white must be used for the text and class number for the CORROSIVE label (See § 172.407(d)(2)).

This Office does not perform extensive compliance reviews of the design and color of hazard warning labels required on packages of hazardous materials for transportation in
commerce. We are returning all of your labels in the two envelopes you enclosed for this purpose.

I hope this information is helpful. If we can be of further assistance, please contact us.


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

172.407, 172.411 through 172.448

Regulation Sections

Section Subject
§ 172.411 EXPLOSIVE 1.1, 1.2, 1.3, 1.4, 1.5 and 1.6 labels, and EXPLOSIVE Subsidiary label