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Interpretation Response #99-0026 ([Sakai Trading New York Inc.] [Mr. Y. Goto])

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

Interpretation Response Details

Response Publish Date:

Company Name: Sakai Trading New York Inc.

Individual Name: Mr. Y. Goto

Location State: NY Country: US

View the Interpretation Document

Response text:

MAR 29,1999


Mr. Y. Goto                                              Ref. No. 99-0026
Sakai Trading New York Inc.
317 Madison Avenue, #1601
New York, NY 10017

Dear Mr. Goto:

This is in response to your letter dated January 26, 1999, concerning the display of bilingual text on hazard warning labels under the Hazardous Materials Regulation (HMR; 49 CFR Parts 171-180).  Specifically, you ask whether it is permissible to use another language, in addition to English, for the text on labels.

The answer is yes.  Labels conforming to provisions in the United Nations Recommendations may be used in place of the corresponding labels under the HMR.  Paragraph of the United Nations Recommendations  ( 10th Revised Edition), in limiting text placed on labels to "particulars indicating the nature of the risk and precautions in handling," implies that bilingual inscriptions or text indicating the nature of the risk are acceptable.  However, we interpret this provision as being limited to those inscriptions authorized by a competent authority.  On this basis, if the Japanese government requires such an inscription, it would be allowed.

I hope this satisfies your request.



John A. Gale
Transportation Regulations Specialist
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
172.407 Label specifications