Interpretation Response #10-0090 ([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:
June 9, 2010
Mr. John McQuaid
Industrial Packaging Alliance of North America
P.O. Box 100907
Arlington, VA 22210
Ref. No.: 10-0090
Dear Mr. McQuaid:
This letter clarifies my March 12, 2010 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 request further clarification on the use of a label containing the information required by § 178.503.
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. While this office generally does not recommend the use of a label to display package specification markings on packages likely to undergo reconditioning, this is a performance requirement. Provided you can ensure compliance with these requirements including the ability to withstand the reconditioning process, a printed adhesive label is an acceptable method to display package specification markings in accordance with the HMR. An adhesive label is also an acceptable method to display markings on the top head or side of a drum such as reconditioner markings required by § 178.503(c)(1) or additional markings required by § 178.503(a)(10).
I hope this answers your inquiry. If you have further questions, please do not hesitate to contact this office.
Sincerely,
Charles E. Betts
Chief, Standards Development
Office of Hazardous Materials Standards
178.503(a)(1) through (a)(6) and (a)(i), 178.503(a)(10)
Regulation Sections
| Section | Subject |
|---|---|
| 178.503 | Marking of packagings |