Summary of telephone conversation for docket 

On August 6, 2008 Kimberly Nesci of EPA/OPP received a call about
whether or not devices are required to comply with container-containment
rule labeling requirements.  Based on 40 CFR 152.500, devices are
required to comply with the labeling requirements in 40 CFR part 156,
which includes the container identification language (“Nonrefillable
container.  Do not reuse or refill this container.  Offer for recycling
if available.”)  In many cases, this wouldn’t be necessary for the
packaging for devices (e.g. a box that a black light trap comes in). 
Therefore, exempting devices from the requirements in §156.140 is
possible. 

