Interpretation Response #15-0200 ([Kidde Technologies, Inc.] [Mr. Brett Standifer])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Kidde Technologies, Inc.
Individual Name: Mr. Brett Standifer
Location State: NC Country: US
View the Interpretation Document
Response text:
February 29, 2016
Mr. Brett Standifer
Manager, Fire Extinguishing Engineering
Kidde Technologies, Inc.
4200 Airport Drive NW
Wilson, NC 27896
Ref. No.: 15-0200
Dear Mr. Standifer:
This letter is in response to your August 7, 2015, request for clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the marking requirements for fire extinguishers. Specifically, you ask if the following are considered permanent markings in accordance with § 178.47(q):
Metal hand stamp with low stress type stamps
Laser marking or engraving
Rubber stamp with permanent marking ink
Rubber stamp with permanent marking ink overcoated with clear paint
Vibro hand engraving
Dot Peen machine engraving
Electro-chemical etching/marking
Metal stamping on a metal label and the label affixed to the article with adhesive
As required in § 178.47(q), markings must be stamped plainly and permanently on a permanent attachment or on a metal nameplate and permanently secured to the container by means other than soft solder. All of the methods you described could be permitted as permanent markings on the cylinders provided they do not compromise the integrity of the cylinder and the markings are legible.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
178.47(q)