Interpretation Response #99-0093 ([Clariant Corporation] [Mr. Robert F. Rau])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Clariant Corporation
Individual Name: Mr. Robert F. Rau
Location State: NC Country: US
View the Interpretation Document
Response text:
June 4,1999
Mr. Robert F. Rau Ref. No. 99-0093
Manager, Transportation Regulations
Clariant Corporation
4000 Monroe Road
Charlotte, NC 28205
Dear Mr. Rau:
This is in response to your letter dated March 24, 1999, requesting clarification on labeling requirements under § 172.406 of the Hazardous Materials Regulations HMR; 49 FR Parts 171-180). Specifically, you ask whether affixing the hazard warning label to the surface of a stretch band which is wrapped around the drum would be considered affixing the label to the surface of the package.
This method is acceptable if the plastic band is affixed to the drum and the label is affixed to the plastic, provided the label stays on during conditions normal to transportation. If the labels come of during normal transportation, it would be a violation of the HMR.
I hope this satisfies your inquiry.
Sincerely,
DelmerF.Billings
Chief, Standards Development
Office of Hazardous Materials Standards
172.406
Regulation Sections
| Section | Subject |
|---|---|
| 172.406 | Placement of labels |