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Interpretation Response #11-0172 ([Wiley Rein, LLP] [Mr. George Kerchner])

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

Interpretation Response Details

Response Publish Date:

Company Name: Wiley Rein, LLP

Individual Name: Mr. George Kerchner

Location State: DC Country: US

View the Interpretation Document

Response text:

May 23, 2012



Mr. George Kerchner
Wiley Rein, LLP
1776 K Street, NW
Washington, DC 20006

Ref. No. 11-0172

Dear Mr. Kerchner:

This responds to your July 18, 2011 request for clarification on the specifications for the Class 8 CORROSIVE label under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you ask if the shaded hand on the CORROSIVE label provided in your enclosed photograph complies with §§ 172.407 and 172.442 requirements.
The answer is no. The colors in the photograph you enclosed do not meet the label specification requirements. The label illustration in § 172.442 shows the outline of the hand in black with the hand in white on the white background in the top half of the label. "White," as defined by the American College Dictionary, is an "achromatic color of maximum lightness; as new snow." The variation in the white coloring in the top half of your example is not authorized.

Further, § 172.442(b) specifies that in addition to complying with the label specification requirements found § 172.407, the background of the CORROSIVE label must be white in the top half and black in the lower half. Section 172.407 also requires that the symbol, text, numbers, and border must be shown in black on a label except white must be used for the text and class number for the CORROSIVE label.

I hope this answers your inquiry. If you need additional assistance, please contact this office at (202) 366-8553.



Ben Supko
Acting Chief, Standards Development
Standards and Rulemaking Division

172.407, 172.442

Regulation Sections

Section Subject
172.407 Label specifications
172.442 CORROSIVE label