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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

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.



Hattie L. Mitchell, Chief
Regulatory Review and Reinvention
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
172.401 Prohibited labeling