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Interpretation Response #10-0062 ([Air Liquide America Specialty Gases LLC] [Mr. Ralph Diaz])

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

Interpretation Response Details

Response Publish Date:

Company Name: Air Liquide America Specialty Gases LLC

Individual Name: Mr. Ralph Diaz

Location State: TX Country: US

View the Interpretation Document

Response text:

December 2, 2010



Mr. Ralph Diaz

Air Liquide America Specialty Gases LLC

2700 Post Oak Blvd.

Houston, TX 77056

Reference No. 10-0062

Dear Mr. Diaz:

This is in response to your e-mail, and subsequent conversations and photos pertaining to a clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to marking requirements. Specifically, you ask whether the photos you submitted display marking configurations that meet the proper shipping name and technical name marking requirements applicable to cylinders.

Section 172.301(b) specifies that, except for a Division 6.2 material, technical names must be marked in parentheses and in association with the proper shipping name in accordance with the HMR. As shown in the photographs you forwarded, the technical names appear to be marked in parentheses, in association with the proper shipping name, and not separated by other non-required information in the photographs you forwarded.

I hope this information is helpful. Please contact this office should you have additional questions.


T. Glenn Foster

Chief, Regulatory Review and Reinvention

Standards and Rulemaking Division



Regulation Sections

Section Subject
172.301 General marking requirements for non-bulk packagings