Interpretation Response #12-0153

Interpretation Response Details

October 3, 2012

Mr. Dave Madsen
Hazardous Material Analyst
Autoliv ASP, Inc.
Ogden Assembly Facility
1000 West 3300 South
Ogden, UT 84401

Reference No. 12-0153

Dear Mr. Madsen:

This is in response to your July 13, 2012 letter and August 3, 2012 telephone conversation with a member of my staff concerning the CLASS 9 miscellaneous hazard class warning label. Specifically, you ask whether the dotted line that appears as the outer border of the label"s image in § 172.446 may be replaced with a solid black line under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).

The answer is yes. The HMR requires a dotted or solid line printed as the outer border of a hazard warning label prescribed in 49 CFR Part 172, Subpart E, if the label is printed on or affixed to a background of similar color (see § 172.406(d)). However, please note that under the HMR, the dotted line border that is shown on all hazard warning labels prescribed in 49 CFR Part 172, Subpart E, is not a part of the label"s specification unless it is used as an alternative for the solid line outer border in the manner prescribed in § 172.406(d) (see § 172.407(b)(2)).

I hope this satisfies your request.

Sincerely,

T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
172.446, 172.406, 172.407

Regulation Sections