Label Solutions, Inc. — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 1200 New Jersey Avenue, SE Materials Safety Pipeline and Hazardous Washington, D.C. 20590 Administration OCT 2 0 2016 Ms. Tammy King Label Solutions, Inc. P.O. Box 12 Marshfield, MO 65706 Reference No. 16-0089 Dear Ms. King: This letter is in response to your May 18, 2016, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to cylinder labels. You note that Compressed Gas Association (CGA) C-7, Appendix A, A.4, indicates that the hazard class text (e.g., "flammable gas") is not required but is allowed by the HMR. Specifically, you ask if is it acceptable for the words "flammable gas" —when placed in the transportation diamond as illustrated in CGA C-7, Appendix A—to be on two lines rather than one line as it appears in § 172.417 of the HMR. The answer is no. The HMR allow exceptions to labeling under § 172.400a for a cylinder containing a Division 2.1, 2.2, or 2.3 material that is durably and legibly marked in accordance with CGA C-7, Appendix A. In addition, cylinders containing a flammable gas the HMR allow the hazard class text to be displayed on two lines. can use the label prescribed in § 172.417 of the HMR. Neither CGA C-7, Appendix A, nor I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, I er Taste T. Glenn Foster Standards and Rulemaking Division Chief, Regulatory Review and Reinvention Branch#

Page 2Andans 172417 Goodall, Shante CTR (PHMSA) Flammable, GAs Label From: Sent: Rivera, Jordan CTR (PHMSA) 16-0089 To: Wednesday, May 18, 2016 3:35 PM Subject: Hazmat Interps FW: Request for letter of interpretation Hi Shante/Alice, Please submit this for a letter of interpretation. I spoke with Ms. King. Please let me know if you have any questions. Thanks, Jordan From: Tammy King [mailto:tking@easylabeling.com] To: INFONTR (PHMSA) Sent: Wednesday, May 18, 2016 10:40 AM Subject: Request for letter of interpretation To Whom It May Concern, I am writing to request a letter of interpretation regarding the format of the transportation diamond as used in the CGA C-7 marking system as outlined in the CGA C-7 Appendix A section A.8. The CGA C-7 Appendix A A.4 mentions that hazard class words are not required but are allowable. In section A.8 on the illustrative example does not contain the word "gas" but it is noted that the word may be included but does not specify where inside the diamond it should be placed. My question is, when using the hazard class words in the transportation diamond (e.g. flammable gas) as it appears in 49 CFR 172.417 in the illustrated example for labeling? illustrated in CGA C-7 Appendix A, is it acceptable for the words to be on two lines rather than one line as Regards, Tammy King Label Solutions, Inc. P.O. Box 12 Marshfield, MO 65706 417.859.6850 Ext 255 tking@easvlabeling.com#