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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #12-0071 ([Industrial Packaging Alliance of North America] [Mr. John McQuaid])

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

Interpretation Response Details

Response Publish Date:

Company Name: Industrial Packaging Alliance of North America

Individual Name: Mr. John McQuaid

Location State: VA Country: US

View the Interpretation Document

Response text:

May 30, 2012



Mr. John McQuaid
Industrial Packaging Alliance of North America
P.O. BOX 100907
Arlington, VA 22210-3907

Reference No.: 12-0071

Dear Mr. McQuaid:

This responds to your March 6, 2012 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the marking of steel drums. Specifically, you ask if a manufacturer is permitted to use a three-line mark instead of a four-line mark that contains the pertinent information without listing the month of manufacture, US origin, and M-number twice.

The answer is no. Section 178.503(a) states that the packaging must bear the marks as specified in (a)(1) through (a)(6) of this section. It then states that the marking may be applied in a single line or in multiple lines provided the correct sequence is used. In removing the month of manufacture, US origin, and M-number as shown in your letter, the marking would no longer meet the requirements of § 178.503(a) which requires that the information on the marking be presented in the correct sequence, and, therefore would not be in compliance with the HMR.

I hope 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
178.503 Marking of packagings