Interpretation Response #99-0127 ([Federal-Mogul Power train Systems] [Mr. Scott Holder])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Federal-Mogul Power train Systems
Individual Name: Mr. Scott Holder
Location State: WI Country: US
View the Interpretation Document
Response text:
JUL 26, 1999
Mr. Scott Holder Ref. No. 99-0127
Federal-Mogul Power train Systems
P.O. Box 910
Manitowoc, WI 54221-0910
Dear Mr. Holder:
This is in response to Mr. Peter Madden’s letter regarding the requirements under the Hazardous Material Regulations (HMR; 49 CFR Parts 171-180) applicable to the use of paint to obliterate labels on non-bulk packagings. Mr. Madden requested that we address the response to you.
Specifically, Mr. Madden asked whether the use of paint to cover non-applicable labels is acceptable, or must the label be removed. He stated that only required DOT markings and labels would be visible on the packages. The packages contain hazardous waste prepared for transportation in accordance with the provisions in §§ 173.12(c) and 173.28 (6).
The HMR does not prohibit the use of spray paint to completely obliterate non-applicable labels. Such non-applicable labels must be obliterated, removed or securely covered during transportation. Markings and labels such as for advertising are permitted, provided they do not obscure or cause confusion with any required marking or label.
I hope this information is helpful. If you need further assistance, please do not hesitate to contact this office.
Sincerely,
Hattie L. Mitchell, Chief
Regulatory Review and Reinvention
Office of Hazardous Materials Standards
172.401
Regulation Sections
| Section | Subject |
|---|---|
| 172.401 | Prohibited labeling |