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Interpretation Response #16-0089 ([Label Solutions, Inc.] [Ms. Tammy King])

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

Interpretation Response Details

Response Publish Date:

Company Name: Label Solutions, Inc.

Individual Name: Ms. Tammy King

Location State: MO Country: US

View the Interpretation Document

Response text:

October 20, 2016

Ms. Tammy King
Label Solutions, Inc.
P.O. Box 12
Marshfield, MO  65706

Reference No. 16-0089

Dear Ms. King:

This letter is in response to your May 18, 2016, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to cylinder labels.  You note that Compressed Gas Association (CGA) C-7, Appendix A, A.4, indicates that the hazard class text (e.g., “flammable gas”) is not required but is allowed by the HMR.  Specifically, you ask if is it acceptable for the words “flammable gas”—when placed in the transportation diamond as illustrated in CGA C-7, Appendix A—to be on two lines rather than one line as it appears in § 172.417 of the HMR.  

The answer is no.  The HMR allow exceptions to labeling under § 172.400a for a cylinder containing a Division 2.1, 2.2, or 2.3 material that is durably and legibly marked in accordance with CGA C-7, Appendix A.  In addition, cylinders containing a flammable gas can use the label prescribed in § 172.417 of the HMR.  Neither CGA C-7, Appendix A, nor the HMR allow the hazard class text to be displayed on two lines.

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
172.417, 172.400a

Regulation Sections

Section Subject
172.400a Exceptions from labeling
172.417 FLAMMABLE GAS label