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Interpretation Response #10-0033 ([Industrial Packaging Alliance of North America] [Mr. John McQuaid])

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

Interpretation Response Details

Response Publish Date:

Company Name: Industrial Packaging Alliance of North America

Individual Name: Mr. John McQuaid

Location State: VA Country: US

View the Interpretation Document

Response text:

March 12, 2010




Mr. John McQuaid

Industrial Packaging Alliance of North America

P.O. Box 100907

Arlington, VA 22210

Ref. No.: 10-0033

Dear Mr. McQuaid:

This is in response to your January 21, 2010 letter regarding display of package markings in accordance with the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether a label containing the information required by § 178.503(c) meets the permanency requirements of § 178.3.

A reusable metal drum liable to undergo a reconditioning process must bear the marks identified in § 178.503(a)(1) through (a)(6) and (a)(9)(i) in a permanent form that is able to withstand the reconditioning process. Although it may be possible to permanently apply these marks in some other fashion (e.g. stamping or etching), embossing is the most common method of permanently marking steel drums. A label generally would not insure permanency.

For a new metal drum with a capacity greater than 100 L, the permanent marks described in

§ 178.503(a)(1) through (a)(6) and (a)(9)(i), must appear on the bottom. Other required marks need not be permanent and may appear as part of a complete marking on the side or top of the drum. Again, a label generally would not insure permanency. If the capacity of the drum is less than or equal to 100 L the markings may be anywhere on the drum.

I hope this answers your inquiry. If you have further questions, please do not hesitate to contact this office.


Charles E. Betts

Chief, Standards Development

Office of Hazardous Materials Standards

178.3, 178.503(c)

Regulation Sections

Section Subject
178.503 Marking of packagings