Serenity Packaging Corporation — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration DEC - 2 2010 1200 New Jersey Ave, SE Washington, D.C. 20590 Mr. Jerry Loza Quality Coordinator Serenity Packaging Corporation 1601 East Main Street, Suite 2E St. Charles, 1160174 Reference No. 10-0168 Dear Mr. Loza: This is in response to your e-mail asking for clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the requirements for labels. You submitted an example of a corrosive label that appears to be printed directly on the surface of a package. You ask whether the depicted label meets the HMR labeling requirements regarding the white and black colors. The answer is no. Section 172.442(b) specifies that in addition to complying with the label specification requirements found in § 172.407, the background of the corrosive label must be white in the top half and black in the lower half. The colors in the pictorial you submitted do not meet these requirements. "White," as defined by the American College Dictionary, is an achromatic color of maximum lightness; as new snow. The variations in the black coloring in the lower halfof your example also are not authorized. "Black," as defined by the American College Dictionary, is an achromatic color value of minimum lightness or maximum darkness; darkest hue. I hope this information is helpful. Please contact this office should you have additional questions. Sincerely, T. Glenn Foster Chief, Regulatory Review and Reinvention Standards and Rulemaking Division#

Page 2Drakeford, Carol n From: INFOCNTR (PHMSA) (7Z ZI Sent: Monday, August 02, 2010 1 :35 PM Jo: Drakeford, Carolyn (PHMSA) 9/72. 10 1 Subject: FW: Interpretation 2 'Attachments: worse case of printJPG LaiJeI;:::; I()" o/¢'%Hi Carolyn, Jerry Loza is requesting an official letter of interpretation. Previously, he spoke with HMIC staff and was referred to letters 07-0146 and 01-0029. Thanks, Victoria Lehman Hazmat Information Center 202-366-1035 From: Jerry Loza [mailto:jerry.loza@serenitypkg.com] Sent: Monday, August 02, 2010 11:08 AM To: INFDCNTR (PHMSA) Subject: Interpretation 2 We would like an official interpretation to determine if this print meets the D.D.T. guidelines. I did not find Pantone guidelines for black or white print. Please call if there are any questions. $erryIo.za Serenity Packaging Corporation Quality Coordinator Ph 630-762-9870 x-2237 Fax 630-762-9873 1601 East Main Street Suite 2E St. Charles, II 60174 1#

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