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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.






Charles E. Betts

Chief, Standards Development

Office of Hazardous Materials Standards


178.3, 178.503, 173.28(b)(4)


Regulation Sections

Section Subject
173.28 Reuse, reconditioning and remanufacture of packagings
178.503 Marking of packagings