Specialty Industries — Hazardous Materials Safety Interpretation

Page 1f Transportatio S. Departmer 400 Seventh St., S.W. Research and Washington, D.C. 20590 Administration special Programs FEB 2 8 2003 Mr. Marc Caron Packaging/Sales Engineer Reference No. 03-0046 Specialty Industries 175 East Walnut St. Red Lion, PA 17356 Dear. Mr. Caron: This is in response to your letter concerning the placement of UN markings displayed on a 4G fiberboard box under § 178.503 of the Hazardous Materials Regulations (49 CFR Parts 171-180). Specifically, you ask whether the placement of the markings, applied in a single line but with the year of manutacture offsetted and placed to the right of the other markings, is acceptable. Additionally, you ask if the markings are not acceptable could a custom label bearing the enclosed a photograph of the marked packaging for our review. required markings in a single line as illustrated in be used to cover the incorrect markings. You Your packaging markings, as represented on the photograph, does not satisfy the marking readily associated with the other markings. You may use a custom label bearing the required requirements in § 178.503 as placement of the year of manufacturer is confusing and is not markings as you suggest, or cover or obliterate the printed year of manufacture and re-mark the § 178.503(e) (2). year of manufacture next to and in alignment with the other markings as shown ir I hope this satisfies your request. Sincerely, Aithe z. Michell Hattie L. Mitchell, Chief Regulatory Review and Reinvention Office of Hazardous Materials Standards Enclosure 178503 030046#

Page 2: Betts § 178.3 Marc Caron ackaging/Sales Enginee 175 East Walnut St. pecialty Industrie 3178.503 Red Lion, PA 17356 Marking.of Director, Office of Hazardous Materials Standards Edward T. Mazzullo Packagings 03-0046 Washington, DC 20590-0001 Dear Mr. Mazzullo: This letter comes to you after having spoken to a representative in the Hazardous Materials Information Pennsylvania. We are required by a few of our customers to include the UN Designation (UN 4G/Y**/S*) Center. I am a packaging/sales engineer, employed by a small corrugated box manufacturer in Central bulk performance oriented packagings found in § 178.503 of the Hazardous Materials Regulations (HMR per 49 CrRy markings on our boxes. Specifically, the specification marking requirements for non- 49 CFR Parts 171-180). A recent complaint has come across the desk of our Quality Coordinator. The complaint is in reference to equired, but "offset" to the right, for lack of a better word, and not in line with the rest of the requires he year or manufacture (" = the last two digits of the calendar year) marking. The marking is on the box a markings. (Please see attached photo.) In speaking to your representative, I have asked two questions: 1) As seen in the picture, are the current markings (particularly the year of manufacture, in this case 03) acceptable? If the markings are not acceptable, is a custom label with all required markings placed over the area you see in the picture an acceptable alternative? I've been told that although all the required information and markings are present on the box, the year of manufacture marking may cause confusion or rejection by an inspector. With that said, I have been told the are authorized. use of permanent self-adhesive markings, containing the specification markings that comply with § 178.3, We do not want to scrap the rejected order. Instead, I am requesting a formal written response to my I want to dant you a act for can the in do any eager use sold you necd further Sincerely, Marc Caron Specialty Industries Office: 717-246-1661 Packaging/Sales Engineer Cell: 717-880-6311 Email: macron@specialtyindustries.com#

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