Interpretation Response #12-0034
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
April 3, 2012
Mr. Steven Powell
Container-Quinn Testing Laboratories, Inc.
A Division of Holmes Testing, Inc.
170 Shepard Avenue
Wheeling, IL 60090
Ref. No. 12-0034
Dear Mr. Powell:
This responds to your January 26, 2012 request for written clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the marking of non-bulk performance-oriented packagings. Specifically, you ask whether the HMR may prevent you from registering your company"s symbol (e.g., CQ) as an approved marking in lieu of an "M" number.
As stated in § 178.503(a)(8), symbols used in place of the manufacture"s name and address must be registered with the Associate Administrator (AA) for Hazardous Materials Safety. All registered symbols must be approved under § 107.705. This section provides the AA the authority to require the use of a certain type of symbol for marking of non-bulk performance-oriented packagings. Currently, PHMSA"s policy is to issue "M" numbers in order to provide consistency among symbols used and approved by approval agencies.
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
|§ 178.503||Marking of packagings|