You are here

Interpretation Response #12-0034


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

Interpretation Response Details

Response Publish Date: 04-03-2012
Company Name: Container-Quinn Testing Laboratories, Inc. A Division of Holmes Testing, Inc.    Individual Name: Mr. Steven Powell
Location state: IL    Country: US

View the Interpretation Document


Response text:

April 3, 2012

 


Mr. Steven Powell
Director
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.


Sincerely,

 


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


178.503, 107.705


Regulation Sections

Section Subject
§ 178.503 Marking of packagings