THE LETTERS

摘要

This letter is in response to your September 3, 2020, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to marking and labeling requirements for propane tanks. In your email, you state that your client is a company that manufactures large propane tanks ranging in size from approximately 6 feet long and 3 feet high, to approximately 24 feet long and 5 feet high. You state that your client ships these propane tanks new, empty, and with shrink-wrapped valves. You also state that your client would like to adhere an accompanying label/marking to each propane tank, and you have included a picture of the label/marking along with your email. As shown in the picture, the top of the rectangular label/marking has a large red banner that contains an exclamation mark inside of a white triangle and the word "DANGER," the left-hand side has a black and white flame symbol, and the right-hand side contains an "explosion hazard" warning as well as additional warnings for other problems owners should be aware of described in plain text. Specifically, you ask whether it would be a violation of the HMR to adhere the warning label/marking described above to a propane tank.