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Interpretation Response #98-0597 ([The Association of Container Reconditioners] [Mr. Paul Rankin])

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

Interpretation Response Details

Response Publish Date:

Company Name: The Association of Container Reconditioners

Individual Name: Mr. Paul Rankin

Location State: MD Country: US

View the Interpretation Document

Response text:

MAY 4, 1998


Mr. Paul Rankin, President
The Association of Container Reconditioners
8401 Corporate Drive, Suite 140
Landover, MD 20785-2224

Dear Mr. Rankin:


This is in response to your letter of May 28, 1997, and your telephone conversation with Mr. Charles Betts of my staff, requesting clarification on the Hazardous Materials Regulations (HMR; 49 CFRParts 171-180) concerning the modification of markings displayed on a durable preprinted label and affixed to, the side of a reconditioned steel drum. You state that drum reconditioners stock the more commonly used markings (i.e., preprinted labels). Sometimes slightly different markings are needed for a reconditioned drum. You ask whether a reconditioner can use an indelible marker to change the preprinted markings to show a higher performance capability provided that the altered markings never exceed the manufacturer's permanent mark, for example, changing the preprinted marking "UN lAl/Y1.2/l00" to read "UN lAl/Y1.4/l00."

The answer is yes. Using a permanent ink to alter the markings on the label is acceptable if the requirements specified in § 178.3 (a)(3) for permanency, contrast, and legibility are met. However, you should be aware that a manual change to a printed label may be viewed with suspicion by persons using, handling or inspecting the drums. Also, as you stated and as prescribed by § 173.24 (c)(4), in no case may the markings applied by the reconditioner identify a greater performance capability than that marked on the drum by the manufacturer.

I hope this information is helpful. Should you have further questions, do not hesitate to contact us.



Edward T. Maz:ullo
Director, Office of Hazardous
Materials Standards


Regulation Sections

Section Subject
178.503 Marking of packagings