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Interpretation Response #09-0034 ([Challenge, Inc.                                                    ] [Mr. Keith Hauser                                                        ])

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

Interpretation Response Details

Response Publish Date:

Company Name: Challenge, Inc.                                                    

Individual Name: Mr. Keith Hauser                                                        

Location State: IN Country: US

View the Interpretation Document

Response text:

March 31, 2009

 

 

 

 

 

 

Mr. Keith Hauser                                                        

Technical Manager

Challenge, Inc.

7950 Georgetown Road

Indianapolis, IN   46268

 

 Ref. No.: 09-0034

 

Dear Mr. Hauser:

 

This responds to your January 27, 2009 request for clarification of requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the marking of reconditioned drums.  Specifically, you ask whether a sticker is sufficient to mark reconditioned drums in accordance with § 178.503(c).

 

The answer is yes.  Marking a reconditioned drum with a permanent label printed with permanent ink to meet the requirements of § 178.503(c) is acceptable provided the marking also meets the requirements specified in § 178.3 for adequate accessibility, permanency, contrast, and legibility. 

 

Note, however, that, as specified in § 173.28(b)(4), metal and plastic drums used as single packagings or the outer packagings of composite packagings are authorized for reuse only when they are marked in a permanent manner with the nominal or minimum thickness of the packaging material.  This marking must be capable of surviving the reconditioning process; embossing is one acceptable method.  See § 178.503(a).

 

I hope this answers your inquiry.

 

Sincerely,

 

 

 

Charles E. Betts

Chief, Standards Development

Office of Hazardous Materials Standards

 

178.3, 178.503, 173.28(b)(4)

 

Regulation Sections