{"operation":"document","citation":"03-0046","title":"Specialty Industries — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2003-02-28","effective_on":null,"summary":"03-0046 response to Specialty Industries concerning 178.503.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-03-0046.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-03-0046.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-03-0046","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2003/030046.pdf","body":"<<<PAGE 1>>>\n\nf Transportatio\nS. Departmer\n400 Seventh St., S.W.\nResearch and\nWashington, D.C. 20590\nAdministration\nspecial Programs\nFEB 2 8 2003\nMr. Marc Caron\nPackaging/Sales Engineer\nReference No. 03-0046\nSpecialty Industries\n175 East Walnut St.\nRed Lion, PA 17356\nDear. Mr. Caron:\nThis is in response to your letter concerning the placement of UN markings displayed on a 4G\nfiberboard box under § 178.503 of the Hazardous Materials Regulations (49 CFR Parts 171-180).\nSpecifically, you ask whether the placement of the markings, applied in a single line but with the\nyear of manutacture offsetted and placed to the right of the other markings, is acceptable.\nAdditionally, you ask if the markings are not acceptable could a custom label bearing the\nenclosed a photograph of the marked packaging for our review.\nrequired markings in a single line as illustrated in be used to cover the incorrect markings. You\nYour packaging markings, as represented on the photograph, does not satisfy the marking\nreadily associated with the other markings. You may use a custom label bearing the required\nrequirements in § 178.503 as placement of the year of manufacturer is confusing and is not\nmarkings as you suggest, or cover or obliterate the printed year of manufacture and re-mark the\n§ 178.503(e) (2).\nyear of manufacture next to and in alignment with the other markings as shown ir\nI hope this satisfies your request.\nSincerely,\nAithe z. Michell\nHattie L. Mitchell, Chief\nRegulatory Review and Reinvention\nOffice of Hazardous Materials Standards\nEnclosure\n178503\n030046\n\n<<<PAGE 2>>>\n\n:\nBetts\n§ 178.3\nMarc Caron\nackaging/Sales Enginee\n175 East Walnut St.\npecialty Industrie\n3178.503\nRed Lion, PA 17356\nMarking.of\nDirector, Office of Hazardous Materials Standards\nEdward T. Mazzullo\nPackagings\n03-0046\nWashington, DC 20590-0001\nDear Mr. Mazzullo:\nThis letter comes to you after having spoken to a representative in the Hazardous Materials Information\nPennsylvania. We are required by a few of our customers to include the UN Designation (UN 4G/Y**/S*)\nCenter. I am a packaging/sales engineer, employed by a small corrugated box manufacturer in Central\nbulk performance oriented packagings found in § 178.503 of the Hazardous Materials Regulations (HMR\nper 49 CrRy markings on our boxes. Specifically, the specification marking requirements for non-\n49 CFR Parts 171-180).\nA recent complaint has come across the desk of our Quality Coordinator. The complaint is in reference to\nequired, but \"offset\" to the right, for lack of a better word, and not in line with the rest of the requires\nhe year or manufacture (\" = the last two digits of the calendar year) marking. The marking is on the box a\nmarkings. (Please see attached photo.)\nIn speaking to your representative, I have asked two questions:\n1)\nAs seen in the picture, are the current markings (particularly the year of manufacture, in this\ncase 03) acceptable?\nIf the markings are not acceptable, is a custom label with all required markings placed over\nthe area you see in the picture an acceptable alternative?\nI've been told that although all the required information and markings are present on the box, the year of\nmanufacture marking may cause confusion or rejection by an inspector. With that said, I have been told the\nare authorized.\nuse of permanent self-adhesive markings, containing the specification markings that comply with § 178.3,\nWe do not want to scrap the rejected order. Instead, I am requesting a formal written response to my\nI want to dant you a act for can the in do any eager use sold you necd further\nSincerely,\nMarc Caron\nSpecialty Industries\nOffice: 717-246-1661\nPackaging/Sales Engineer\nCell:\n717-880-6311\nEmail: macron@specialtyindustries.com\n\n<<<PAGE 3>>>\n\n4G/Y24/S/\n03\nUSA/HEDWIN\nBALTIMORE, MD 21211","truncated":false,"body_characters":3783}