{"operation":"document","citation":"03-0235","title":"Mr. Lonnie Harrington — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2004-11-04","effective_on":null,"summary":"03-0235 concerning 178.703.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-03-0235.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-03-0235.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-03-0235","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2003/030235.pdf","body":"<<<PAGE 1>>>\n\nof Transportction\nU.S. Department\n400 Seventh St., S.W.\nWashington, D.C. 20590\nResearch and\nSpecial Programs\nNOV 4 2004\nAdministration\nMr. Lonnie Harrington\n306 Aundria Drive\nRef. No. 83-0235\nLafayette, LA 70503\nDear Mr. Harr ngton:\nprescribed in §§ 178.3 and 178.703 of the Hazardous Materials Regulations (HMR; 49 CFR\nParts 171-180). You said Mr. Kurt Eichenlaub, a member of our staff, stated to you in a\ntelephone conversation he believed the label you described would meet these criteria.\nIn a September 27, 2004 telephone conversation with Ms. Eileen Edmonson of my staff, you\nstated the label has a slick coating, cannot be torn, and is sewn on with a heavy density thread.\nprovide this of ice with a example of the label product, but we have not received this material to\nYou also stated in your letter and in your conversation with Ms. Edmonson that you would\ndate. We apologize for the delay in responding and any inconvenience this may have caused.\nBased on the information you provided, it is this office's opinion the printed Tyvec paper label\nyou described that is properly sized and marked with the DOT specification or UN standard\nsymbols and language required under the HMR for the hazardous material and packaging type\nwill meet the criteria for permanency under § 178.3(a)(3) provided the Tyvec label is secured to\na non-removable component of the FIBC in a manner that cannot be removed easily, e.g., if all\nfour outer sides of the Tyvec paper label were sewn to the FIBC. It is also our opinion the\nprinted Tyvec paper label meets the criteria for a \"durable\" marking under § 178.703(a)(1)\nintroductory paragraph.\nI hope this satisfies your request.\nSincerely,\nNatte z. Mittell\nHattie L. Mitchell, Chief\nRegulatory Review and Reinvention\nOffice of Hazardous Materials Regulations\n178.3 (a) 3)\n178.703 (a)(\n030235\n\n<<<PAGE 2>>>\n\n9/25/03\nEdmonson\nLonnie Harrington\n306 Aundria Dr.\n3178,3 (a 3)\nLafayette, LA 70503\nand $/ 78.703 a X1)\nMarking\nGood Morning,\n03-0235\nIn speaking to representative, Kurt, this AM I was inquiring\nas to what is considered under 178.3 (a) ...\"must be marked\non a non-removable component of the packaging..\" a\npermanent label that the UN markings can be printed on.\nWhat I discussed was sewing on to an FIBC is a Tyvec label\nwith markings as referenced in section 178.703\n(...\"pictogram displaying recommended lifting methods..\")\nand below the pictures, print the UN required numbers\n(178.503) 12mm or larger.\nIn other words we actually sew the label on to the bag during\nthe manufacturing process on this Tyvec label (quality cloth\ntype label that accepts print readily):\nI am looking for his response via e-mail, in prelude to getting\nwritten formal response. The formal response can be sent to\nthis e-rail address or address:\nThanking you in advance for a quick response in this matter.\nRegards,\nLonnie Harrington","truncated":false,"body_characters":2875}