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Interpretation Response #11-0275 ([American Coatings Association, Inc.] [Ms. Heidi K. McAuliffe, Esq.])

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

Interpretation Response Details

Response Publish Date:

Company Name: American Coatings Association, Inc.

Individual Name: Ms. Heidi K. McAuliffe, Esq.

Country: US

View the Interpretation Document

Response text:

December 22, 2011

Ms. Heidi K. McAuliffe, Esq.
Senior Counsel
American Coatings Association, Inc.
1500 Rhode Island Avenue, N.W.
Washington, DC 20005

Ref. No. 11-0275

Dear Ms. McAuliffe:

This responds to your November 3, 2011 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the continued use of previously- authorized marked packagings as prescribed in 172.300(c). You ask whether a packaged limited quantity displaying a United Nations (UN) Identification Number within a square-on-point marking, authorized on December 31, 2011 as prescribed in § 172.315, may continue to be marked as such until December 31, 2012 under the transitional provisions in § 172.300(c).

The answer is yes. As you correctly point-out in your letter, § 172.300(c) provides for the continued use of packaging stock printed prior to the compliance date of a marking amendment in a final rule for an additional year, or until depleted, whichever is less. Provided the packagings are marked in the manner previously-authorized, they may be used for an additional year under the conditions specified in § 172.300(c).

I trust this satisfies your inquiry. Please contact us if we can be of further assistance.


T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

Regulation Sections

Section Subject
172.300 Applicability
172.315 Limited quantities