{"operation":"document","citation":"11-0250","title":"W.M. Barr & Company — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2011-11-22","effective_on":null,"summary":"11-0250 response to W.M. Barr & Company concerning 172.406.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-11-0250.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-11-0250.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-11-0250","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2011/110250.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration\n1200 New Jersey Ave, SE\nWashington, D.C. 20590\nNOV 2 2 2011\nJohn Rhodes\nPackaging Engineer\nW.M. Barr & Company\nP.O. Box 1879\nMemphis, TN 38101\nReference No.: 11-0250\nDear Mr. Rhodes:\nThis is in response to your October 3, 2011 letter requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) as they pertain to label placement. You\nhave provided a picture of a package labeled with a flammable liquid label that has one corner of\nthe square on point extending onto a separate side panel of the package. You ask if this example\nconstitutes a violation of § 172.406(f).\nIt is the opinion of this office that the label placement pictured in the photograph you submitted is\nnot in violation of § 172.406(f). The requirements for label visibility in § 172.406(f) require that\nlabels must be clearly visible and may not be obscured by markings or attachments. The intent of\nthis requirement is to ensure that hazard communication labels clearly illustrate the hazards\npresented within the package, and that the view of the required label is not obstructed by any\nadditional markings or packaging accessories that may reduce the effectiveness of the required\nhazard communication. The slight overlap of the label in the picture you provided does not reduce\nthe effectiveness of the label to convey the hazards represented within the package.\nI hope this satisfies your inquiry. Please contact us if we can be of further assistance.\n~ ~ ~\nDelmerBilU\nSenior Regulatory Advisor\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\n. Wt~b\n~ 112.. ~D.h(f)\nLa-locd It15\n1/- 7)250~\"arr.\nOctober 3, 2011\nOffice of Hazardous Materials Safety\nPipeline and Hazard Materials Safety Administration\nU.S. Department of Transportation\n1200 New Jersey Avenue SE\nEast Building 2nd Floor\nWashington, DC 20590\nTo Whom It Mat Concern,\nI have enclosed a picture of a box the a flammable diamond affixed in the upper left\ncomer. As you can see, a small portion of the left comer is wrapped around the side of\nthe box. Is this much overlap a violation of 172.406 (f)? Also, the label with the number\nY9116 was not applied by my company.\nI look forward to your response.\nRhodes, Packaging Engineer\n(901) 775-5447\ncc: Attachment\n2105 ChanneliP.O. Box 1879\nMemphis, TN 38113/38101\nPh 901.775.0100\n\n<<<PAGE 3>>>\n\nFLAMMABLE LIQUID\nY9116\n32\nШАС 182","truncated":false,"body_characters":2444}