Interpretation Response #18-0047
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: 220 Laboratories
Individual Name: Eric Fishman
Location State: CA Country: US
View the Interpretation Document
Response text:
February 11, 2019
Eric Fishman
220 Laboratories
2375 3rd Street
Riverside, CA 92507
Reference No. 18-0047
Dear Mr. Fishman:
This letter is in response to your March 19, 2018, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the specification marking on an aerosol can. Specifically, you ask if the “M number” and pressure rating may be marked on the bottom of the can via laser inscription.
The answer is yes. In accordance with § 178.3(a)(1), the marking on a packaging must be in an unobstructed area, with letters and numerals identifying the standards or specification of the packaging. In addition, § 178.3(a) states, “the marking 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.” Furthermore, §§ 178.33-9(a) and 178.33a-9(a) state that the marking must be made by printing, lithographing, embossing or stamping. It is the opinion of this Office that laser inscription is an acceptable method of marking, provided it is accessible, contrasting, and legible. Furthermore, there is no prohibition from marking on the bottom of the can.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division
178.3(a)(1), 178.3(a), 178.33-9(a) and 178.33a-9(a)
Regulation Sections
| Section | Subject |
|---|---|
| 178.3 | Marking of packagings |