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)