Interpretation Response #11-0250 ([W.M. Barr & Company] [Mr. John Rhodes])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: W.M. Barr & Company
Individual Name: Mr. John Rhodes
Location State: TN Country: US
View the Interpretation Document
Response text:
November 21, 2011
Mr. John Rhodes
Packaging Engineer
W.M. Barr & Company
P.O. Box 1879
Memphis, TN 38101
Reference No.: 11-0250
Dear Mr. Rhodes:
This is in response to your October 3, 2011 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) as they pertain to label placement. You have provided a picture of a package labeled with a flammable liquid label that has one corner of the square on point extending onto a separate side panel of the package. You ask if this example constitutes a violation of § 172.406(f).
It is the opinion of this office that the label placement pictured in the photograph you submitted is not in violation of § 172.406(f). The requirements for label visibility in § 172.406(f) require that labels must be clearly visible and may not be obscured by markings or attachments. The intent of this requirement is to ensure that hazard communication labels clearly illustrate the hazards presented within the package, and that the view of the required label is not obstructed by any additional markings or packaging accessories that may reduce the effectiveness of the required hazard communication. The slight overlap of the label in the picture you provided does not reduce the effectiveness of the label to convey the hazards represented within the package.
I hope this satisfies your inquiry. Please contact us if we can be of further assistance.
Sincerely,
Delmer Billings
Senior Regulatory Advisor
Standards and Rulemaking Division
172.406(f)
Regulation Sections
| Section | Subject |
|---|---|
| 172.406 | Placement of labels |