Autoliv ASP, Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue SE Washington. DC 20590 OCT 0 3 2012 Mr. Dave Madsen Hazardous Material Analyst Autoliv ASP, Inc. Ogden Assembly Facility 1000 West 3300 South Ogden, UT 84401 Reference No. 12-0153 Dear Mr. Madsen: This is in response to your July 13, 2012 Jetter and August 3, 2012 telephone conversation with a member of my staff concerning the CLASS 9 miscellaneous hazard class warning label. Specifically, you ask whether the dotted line that appears as the outer border of the label's image in § 172.446 may be replaced with a solid black line under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). The answer is yes. The HMR requires a dotted or solid line printed as the outer border of a hazard warning label prescribed in 49 CFR Part 172, Subpart E, if the label is printed on or affixed to a background of similar color (see§ 172.406(d)). However, please note that under the HMR, the dotted line border that is shown on all hazard warning labels prescribed in 49 CFR Part 172, Subpart E, is not a part of the label's specification unless it is used as an alternative for the solid line outer border in the manner prescribed in § 172.406( d) (see § 172.407(b )(2)). I hope this satisfies your request. T. Glenn Foster Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division#

Page 2Autoliv Edmonson ~ 172. J../b7(b)(z) l-abelJn3 ,~ ... t)/53 July 13, 2012 Mr. Charles Betts Director, Standards & Rulemaking US DOT- PHMSA East Building - 2nc1 Floor 1200 New Jersey Ave. SE Washington, DC 20590 Subject: Request for Interpretation - Hazardous Label Outer Border Dear Mr. Betts, The question has come up as to whether or not a solid black line around a hazard label is allowed as long as it is not part of the overall dimensions of the label. §172.407(b)(2) states; "The dotted line border shown on each label is not part of the label specification ... » If the dotted line is not part of the label then a solid line should also be allowed as long as it is not part of the label. The solid black border for our printers is necessary to account for possible slippage that may occur during the printing process. The label shown below is 100 mm X 100 mm from the ID of the outer black line. The black line is just a border and is not part of the label dimensions. Is this acceptable? Thank you in advance for your help and cooperation in this most important matter. If you have any questions please feel free to contact me at (801)-612-5665, fax (801 )-625-7566 or by email at: Sincerely Yours, Dave Madsen Hazardous Material Analyst Auto!iv ASP, Inc. Ogden Assembly Fac111ty 1000 West 3300 Sat1th Ogden. Ulah US!>. 84401#