Interpretation Response #10-0211 ([CYTEC Industries, Inc.] [Mr. Andrew Bethmann])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: CYTEC Industries, Inc.
Individual Name: Mr. Andrew Bethmann
Location State: SC Country: US
View the Interpretation Document
Response text:
December 15, 2010
Mr. Andrew Bethmann
CYTEC Industries, Inc.
131 Revco Road
North Augusta, SC 29842
Ref. No. 10-0211
Dear Mr. Bethmann:
This responds to your September 24, 2010 request for clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you request clarification on whether the letters "UN" on a printed sticker applied to the side of a 1A1 or 1A2 drum (55 gallons) is acceptable in place of the UN symbol.
The answer is no. As required by § 178.503(a), the permanent marks described in § 178.503(a)(1) through (a)(6) and (a)(9)(i), must appear on the bottom of the packaging. In addition, for packages with a gross mass of more than 66 pounds, the marking on the bottom must also appear on the top or on a side of the packaging. Section 178.503(a)(1) allows the letters "UN" to be embossed on metal receptacles in place of the UN symbol as illustrated in § 178.503(d). Any additional replication of the required UN marking, including stickers used to comply with § 178.3(a)(5) must include the UN symbol, rather than the letters "UN." Marks on the side or top of the drum need not be permanent and may appear as part of a complete marking.
I hope this answers your inquiry. If you need additional assistance, please contact this Office at
202-366-8553.
Sincerely,
Ben Supko
Acting Chief, Standards Development
Standards and Rulemaking Division
178.503
Regulation Sections
| Section | Subject |
|---|---|
| 178.503 | Marking of packagings |