Guidanceguidance
07-0104
Raytheon Technical Services Company — Hazardous Materials Safety Interpretation
Current as of source date Government source
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Page 1of Transportation U.S. Department 1200 New Jersey Ave.. S.E Washington, DC 20590 Pipeline and Hazardous Materials Safety Administration JUL 11 2007 Systems Engineer Mr. James Traylor Ref. No. 07-0104 Raytheon Technical Services Company 6125 East 21$ Street Mail Stop 44 Indianapolis, Indiana 46219 Dear Mr. Traylor: This responds to your May 22, 2007 email requesting clarification of the duplicate labeling provisions of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if you may apply a duplicate label if you do not meet one of the conditions listed in §172.406(e) of the HMR. containment device except under the conditions specified in § 172.406(e) (see The answer is yes. Generally, duplicate labeling is not required on a package or § 172.406(a)(2)). However, nothing in the HMR prohibits the application of duplicate labels. Thus, you may apply duplicate labels to a package even where the conditions specified in § 172.406(e) are not met. If you elect to apply a duplicate label, it is not necessary to also apply a duplicate shipping name marking. I hope this answers your inquiry. Sincerely, Chief. Standards Development Office of Hazardous Materials Standards 172.406 e 72.406 (a)2 070104#
Page 2INFOCNTR <PHMSA> Boothe Sent: From: James Traylor [james_traylor@raytheon.com] Subject: To: INFOCNTR <PHMSA> Tuesday, May 22, 2007 2:21 PM 312.406 (e) REQUEST FOR FORMAL INTERPRETATION 49 CFR 172.406-E Labeling 07-0104 Thank you for reading the over the telephone guidance that exactly answered our question. I called 800-467-4922 and received the favorable answer Therefore this request is being made. However, I need the verbiage read to me over the phone in writing. duplicate label? On 49 CFR 172.406E, if we do not meet any of the 5 listed situations, can we apply a name marking? Is there a requirement that the duplicate label be accompanied by a duplicate shipping The "over the phone" response we a YES, NO, not required. Thank you Systems Engineer, James Traylor Raytheon Technical Services Company, llc Customized 317.306.3379 Engineering and Depot Support Raytheon Technical Serrices Company 6125 F. 215 57. Mail Stop 444 Indianapolis, Fuciana 46219#
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