Interpretation Response #10-0053 ([ATK] [Mr. Christopher J. Widman])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: ATK
Individual Name: Mr. Christopher J. Widman
Location State: MN Country: US
View the Interpretation Document
Response text:
April 22, 2010
Mr. Christopher J. Widman
ATK
7480 Flying Cloud Drive
Minneapolis, MN 55344
Ref. No. 10-0053
Dear Mr. Widman:
This responds to your March 3, 2010 request for clarification of requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180.) applicable to the shipper certification. Specifically, you ask for clarification of § 172.204(a)(1) and our interpretation (Ref. No. 06-0053, dated April 11, 2006) regarding using abbreviations in the certification statement.
In the letter you reference, we state: "The certification statement specified in § 172.204(a)(1) must be written as specified and may not be modified. Therefore, use of the abbreviation "DOT" in lieu of "Department of Transportation" in the shipper's certification statement is unacceptable." You note that the HMR define "DOT" to mean "the Department of Transportation" and ask why the abbreviation may not be used in the certification statement.
Section 172.204 requires a shipper to certify that a hazardous material is offered for transportation in accordance with the HMR using the certification statement in paragraph (a)(1) of that section. The certification is the shipper's legally binding statement of compliance. For clarity and consistency, the certification must appear on the shipping paper exactly as it appears in
§ 172.204(a)(1) or (a)(2). Use of the abbreviation "DOT" in lieu of "Department of Transportation" in the shipper's certification statement is unacceptable.
I hope this answers your inquiry. If you need additional assistance, please contact this Office.
Sincerely,
Charles E. Betts
Chief, Standards Development
Office of Hazardous Materials Standards
172.204
Regulation Sections
| Section | Subject |
|---|---|
| 172.204 | Shipper's certification |