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Interpretation Response #13-0038 ([Monsanto Company] [Mr. David Peters])

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

Interpretation Response Details

Response Publish Date:

Company Name: Monsanto Company

Individual Name: Mr. David Peters

Location State: MO Country: US

View the Interpretation Document

Response text:

April 5, 2013

Mr. David W. Peters
Regulatory Compliance Lead
Monsanto Company
800 North Lindgergh Boulevard
Saint Louis, MO 63167

Reference No.: 13-0038

Dear Mr. Peters:

This is in response to your December 21, 2012 email to the Standards and Rulemaking Division of the Office of Hazardous Materials Safety requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the display of Globally Harmonized System of Classification and Labelling of Chemicals (GHS) labeling in conjunction with hazardous materials placards.

You provide a photograph of a portable tank displaying both GHS labels, and hazardous materials placards. The GHS hazard communication labels are adjacent to the required hazardous materials placards. Ydu ask whether the display of the GHS labels adjacent to the required hazardous materials placards on the tank as depicted would constitute a violation.

The display of the GHS labels on the tank as depicted would not constitute a violation. Section 172.401(c)(5) specifically permits packages that are labeled in conformance with the GHS.

I trust this satisfies your inquiry. Please contact us if we can be of further assistance.



Delmer Billings
Senior Regulatory Advisor
Standards and Rulemaking Division


Regulation Sections

Section Subject
172.401 Prohibited labeling