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Interpretation Response #13-0015R ([Joseph Hamill, P.E.] [U.S. Army ARDEC-Picatinny])

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

Interpretation Response Details

Response Publish Date:

Company Name: Joseph Hamill, P.E.

Individual Name: U.S. Army ARDEC-Picatinny

Location State: NJ Country: US

View the Interpretation Document

Response text:

June 13, 2013

Joseph Hamill, P.E.
ARDEC Project Officer (APO)
40 mm High Velocity Ammunition
U.S. Army ARDEC-Picatinny
Picatinny Arsenal, NJ 07806-5000

Reference No. 13-0015R

Dear Mr. Hamill:

This is in response to your January 22, 2013 e-mail, and your recent telephone conversations with a member of my staff, requesting clarification of marking requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you ask what is the correct meaning of the two-digit number in the fourth position of a performance-oriented marking for a non-bulk, United Nations (UN) standard, 4A steel box packaging.  You enclosed a copy of Department of Defense Drawing 12928042 that states in Note 19 that the asterisk in the marking --“4A/Y22/S/ * /USA/DOD/ AYD”-- must be replaced with the last two digits of the year this steel box is packed with 40mm ammunition cartridges.  You state it is your understanding that the HMR require that these numbers represent the last two digits of the year the packaging is manufactured.  You ask which interpretation is correct.  

Under § 178.503(a)(6), the two numbers in the fourth position of a performance-oriented packaging marking for a non-bulk, UN standard 4A steel box must represent the last two digits of the year this packaging is manufactured.  The HMR do not define the wording “year of manufacture” but this Office has interpreted this wording to mean the following:  

• The “year of manufacture” of single, combination, or composite hazardous materials packaging can be the either the year a packaging is manufactured or assembled.  

Thank you for bringing this matter to our attention.  PHMSA may consider adding a definition for “year of manufacture” to the HMR in a future rulemaking.

I hope this satisfies your request.


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


Regulation Sections

Section Subject
178.503 Marking of packagings