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Interpretation Response #09-0114 ([TRG Inc.] [Mr. Robert E. Sever])

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

Interpretation Response Details

Response Publish Date:

Company Name: TRG Inc.

Individual Name: Mr. Robert E. Sever

Location State: MO Country: US

View the Interpretation Document

Response text:

May 19, 2009





Mr. Robert E. Sever

VP of Engineering

TRG Inc.

4150 Carr Lane Ct.

St. Louis, MO 63119

Ref. No. 09-0114

Dear Mr. Sever:

This is in response to your letters of May 11 and 15, 2009, and our meeting on May 14, concerning colors used by your company to print Oxygen labels onto the sidewalls of cylinders for medical oxygen.

You submitted a number of printed samples of various shades of yellow for the Oxygen label for our review, to determine conformance with the color standards for labels set forth in the Hazardous Materials Regulations (HMR; 49 CFR 171-180) in Subpart E and Appendix A of Part 172. You also submitted an Engineering Report analyzing, by spectrophotometer, 16 samples printed on a cylinder to determine which shade of yellow, if any, would match the central color on the DOT Yellow Color Tolerance Chart. As you indicate in your May 15 letter, it was felt that the test results of a spectrophotometer would be less subjective than comparing color chips.

The test results from the Engineering Report indicate that the number 7 shade of yellow on the sample cylinder is a very close match to the central color on the DOT Yellow Color Tolerance Chart. Based on these results and our review, we agree that sample number 7 is the best color match and conforms to the color standards of the HMR.

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


Edward T. Mazzullo

Director, Office of Hazardous

Materials Standards



Regulation Sections

Section Subject
172.407 Label specifications