COSBO — Hazardous Materials Safety Interpretation

Page 1• of Transportation US. Department 400 Seventh Street, S.W. Research and Washington, D.C. 20590 Special Programs Administration JAN I 4 1999 Mr. Jim Glessner Ref. No. 98-0377 COSBO 1310 Beaver Road Sewickley, PA 15143-2008 Dear Mr. Glessner: This is in response to your letter dated December 14, 1998, regarding whether your modular label, for placement on the shoulder of compressed gas cylinders, is in compliance with the labeling requirements of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You enclosed a sample of your company's modular label system and stated that these labels were modeled after the examples provided in the CGA Pamphlet C-7, Figure 3. As you are aware, a cylinder containing a compressed gas that is not poisonous, carried by a private or contract motor carrier, not overpacked, and durably and legibly marked in accordance with CGA Pamphlet C-7, Appendix A, is excepted from the labeling requirements of the HMR. In accordance with the requirements of 49 CFR 172.400a(a)(1), these markings are recognized as an alternative to labeling under the HMR. Your company's "modular label system" does not meet the requirements in the CGA Pamphlet C-7, Appendix A, Figure 3. Therefore, these modular labels are unacceptable and may not be used to meet the exceptions to labeling specified in 49 CFR 172.400a(a)(1). You may wish to contact the CGA to inquire about getting your "modular label system" incorporated in the CGA system of markings for compressed gas cylinders, or petition for rulemaking under 49 CFR 106.31 to amend the requirements to allow for use of the modular labels. I hope this satisfies your inquiry. Sincerely, She 70140 Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards#