Interpretation ID: aiam0887
Sales Promotion
Stimsonite Division
Amerace-Esna Corp.
3445 North Kimball Avenue
Chicago
Illinois 60618;
Dear Mr. Uding: This is in response to your request for an interpretation of Standar 125, Warning Devices, with respect to the required marking of the date of manufacture on the device. I apologize for the delay in answering your letter. You inquire whether a circular marking in which the last numeral of the year of manufacture is printed inside an inner circle and the month of manufacture is represented by 'small dots' in an outer circle meets the requirements of S5.1.4.; S5.1.4 requires the device to be 'permanently and legibly marked wit ... month and year of manufacture, which may be expressed numerically, as '6/72' ...' The intent of this provision is not only to 'identify subquality batches' to the manufacturer or enforcement personnel, but also to provide the consumer with a clear indication of the date of manufacture in case of a possible defect or failure to meet safety standards. The method of marking the date of manufacture which you propose would not satisfy the language or intent of the requirement, since its meaning would not be clear to the average consumer.; Sincerely, Richard B. Dyson, Assistant Chief Counsel