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Interpretation Response #16-0106 ([Global Logistics] [Ms. Julie Brown])

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

Interpretation Response Details

Response Publish Date:

Company Name: Global Logistics

Individual Name: Ms. Julie Brown

Location State: TN Country: US

View the Interpretation Document

Response text:

December 15, 2016

Ms. Julie Brown
Eastman Chemical Company
Global Logistics
Principal Distribution Safety Representative
200 S. Wilcox Drive
Kingsport, TN 37662-5280

Reference No. 16-0106

Dear Ms. Brown,

This letter is in response to your June 16, 2016, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to background marks, such as stitching, on a preprinted marking, label, or placard. You include in your email photographs showing a white bag that has conductive threading throughout, including within a preprinted Class 9 placard and marine pollutant marking. Specifically, you ask whether visible stitching on a Class 9 placard or label prescribed in §§ 172.560(b) and 172.446(b), respectively, and a marine pollutant marking prescribed in § 172.322(e), is permitted under the HMR.

The answer is yes. In accordance with § 172.322(e)(2), for the marine pollutant marking, the symbol and border must be black on a white or suitable contrasting background. For labels and placards, preprinting is authorized provided the color tolerances in Part 172, Appendix A, Table 3 are met (see § 172.407(d)(4)(i)(B) and § 172.519(d)(3)). Therefore, the HMR permit threading to show through the white background of a marking, label, or placard, as pictured on the preprinted bags provided with your letter.

I hope this information is helpful. Please contact us if we can be of further assistance.



T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

172.560(b), 172.446(b), 172.322(e), 172.322(e)(2), 172.407(d)(4)(i)(B), 172.519(d)(3)

Regulation Sections

Section Subject
172.322 Marine pollutants
172.407 Label specifications
172.446 CLASS 9 label
172.519 General specifications for placards
172.560 CLASS 9 placard