Interpretation Response #13-0238 ([Veolia ES Technical Services LLC] [Mr. Richard Finnegan])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Veolia ES Technical Services LLC
Individual Name: Mr. Richard Finnegan
Location State: MA Country: US
View the Interpretation Document
Response text:
February 5, 2014
Mr. Richard Finnegan
Veolia ES Technical Services LLC
398 Cedar Hill Street
Marlboro, MA 01752
Ref. No. 13-0238
Dear Mr. Finnegan:
This responds to your November 15, 2013 request for clarification of the labeling requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you seek clarification on the requirement for a contrasting background, or a dotted or solid line outer border, specified under § 172.406(d).
According to your letter, a third party wants to place labels for Division 6.1 and Class 9 materials on non-bulk packages that are white in color. Since both the non-bulk packages and Division 6.1 and Class 9 labels are white in color, the labels do not contrast with the background. You ask if a label with a dashed line outer border would comply with the requirements specified in § 172.406(d).
Based on your scenario and enclosed pictures of labels, it is the opinion of this office that your labels comply with § 172.406(d) which requires each label to be printed on or affixed to a background of contrasting color, or have a dotted or solid line outer border.
I hope this answers your inquiry. If you need additional assistance, please contact this office at (202) 366-8553.
Sincerely,
Robert Benedict
Chief, Standards Development Branch
Standards and Rulemaking Division
172.406(d)
Regulation Sections
| Section | Subject |
|---|---|
| 172.406 | Placement of labels |