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Interpretation Response #13-0087 ([Military Surface Deployment and Distribution Command] [Mr. Daniel A. Maham])

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

Interpretation Response Details

Response Publish Date:

Company Name: Military Surface Deployment and Distribution Command

Individual Name: Mr. Daniel A. Maham

Location State: IL Country: US

View the Interpretation Document

Response text:

June 14, 2013

Mr. Daniel A. Maham
Director of Safety
Department of the Army
Military Surface Deployment and Distribution Command
1 Soldier Way
Scott AFB, IL  62225-5006

Reference No.: 13-0087

Dear Mr. Maham:

This is in response to your April 22, 2013 letter 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).  Specifically, you ask whether the use of a label to apply the specification markings to a packaging is permitted by § 178.3.   

The answer is yes, provided the markings meet all applicable requirements of §§ 178.3 and 178.503.

Section 178.3(a)(3) provides, “The markings must be stamped, embossed, burned, printed or otherwise marked on the packaging to provide adequate accessibility, permanency, contrast, and legibility so as to be readily apparent and understood.”

Section 178.503(a) further provides that the markings must be durable, legible and placed in a location and of such a size relative to the packaging as to be readily visible.  Except as otherwise provided every reusable packaging liable to undergo a reconditioning process which might obliterate the packaging marks must bear the marks in a permanent form able to withstand the reconditioning process.

The requirements of §§ 178.3(a)(3) and 178.503(a) cited above are performance requirements.  While this office does not generally recommend the use of a label to display the specification markings on a packaging that is likely to undergo reconditioning, provided you can ensure compliance with the requirements of §§ 178.3 and 178.503, including, if applicable, the ability to withstand the reconditioning process, a label is an acceptable method to display the packaging specification markings.  

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

178.3, 178.503

Regulation Sections

Section Subject
178.503 Marking of packagings