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Interpretation Response #99-0146 ([International Business Machines (IBM)] [Mr. Richard Eggleston])

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

Interpretation Response Details

Response Publish Date:

Company Name: International Business Machines (IBM)

Individual Name: Mr. Richard Eggleston

Location State: NY Country: US

View the Interpretation Document

Response text:

October 5, 1999


Mr. Richard Eggleston                           Ref.  No. 99-0146
Environmental Engineering HRVE
International Business Machines (IBM)
1701 North Street
Endicott, New York 13760

Dear Mr. Eggleston:

This is in response to your letter dated June 1, 1999, regarding the Class 9 label specification under the Hazardous Materials Regulations (HMR;49 CFR Parts 171-180).  Specifically, you inquired whether the color “white”, as depicted on your Class 9 label imprinted on a black poly bag is in conformance with the color tolerances of the HMR.

The color of your Class 9 label does not satisfy the requirements of §§ 172.407 and 172.446 of the HMR.  The background of the Class 9 label is required to be white.  “White” as defined by the American College Dictionary is an achromatic color of maximum lightness; as new snow.

I trust this satisfies your inquiry.  Please contact us if we can be of further assistance.



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


Regulation Sections

Section Subject
172.407 Label specifications