W.M. Barr & Company — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Ave, SE Washington, D.C. 20590 NOV 2 2 2011 John Rhodes Packaging Engineer W.M. Barr & Company P.O. Box 1879 Memphis, TN 38101 Reference No.: 11-0250 Dear Mr. Rhodes: This is in response to your October 3, 2011 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) as they pertain to label placement. You have provided a picture of a package labeled with a flammable liquid label that has one corner of the square on point extending onto a separate side panel of the package. You ask if this example constitutes a violation of § 172.406(f). It is the opinion of this office that the label placement pictured in the photograph you submitted is not in violation of § 172.406(f). The requirements for label visibility in § 172.406(f) require that labels must be clearly visible and may not be obscured by markings or attachments. The intent of this requirement is to ensure that hazard communication labels clearly illustrate the hazards presented within the package, and that the view of the required label is not obstructed by any additional markings or packaging accessories that may reduce the effectiveness of the required hazard communication. The slight overlap of the label in the picture you provided does not reduce the effectiveness of the label to convey the hazards represented within the package. I hope this satisfies your inquiry. Please contact us if we can be of further assistance. ~ ~ ~ DelmerBilU Senior Regulatory Advisor Standards and Rulemaking Division#

Page 2. Wt~b ~ 112.. ~D.h(f) La-locd It15 1/- 7)250~"arr. October 3, 2011 Office of Hazardous Materials Safety Pipeline and Hazard Materials Safety Administration U.S. Department of Transportation 1200 New Jersey Avenue SE East Building 2nd Floor Washington, DC 20590 To Whom It Mat Concern, I have enclosed a picture of a box the a flammable diamond affixed in the upper left comer. As you can see, a small portion of the left comer is wrapped around the side of the box. Is this much overlap a violation of 172.406 (f)? Also, the label with the number Y9116 was not applied by my company. I look forward to your response. Rhodes, Packaging Engineer (901) 775-5447 cc: Attachment 2105 ChanneliP.O. Box 1879 Memphis, TN 38113/38101 Ph 901.775.0100#

Page 3FLAMMABLE LIQUID Y9116 32 ШАС 182#