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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



Ben Supko

Acting Chief, Standards Development

Standards and Rulemaking Division


Regulation Sections

Section Subject
178.503 Marking of packagings