Interpretation Response #98-0224 ([H.B. Fuller Automotive Company] [Mr. Eugene J. Secor])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date: 08/14/1998

Company Name: H.B. Fuller Automotive Company

Individual Name: Mr. Eugene J. Secor

Location State: MI Country: US

View the Interpretation Document

Response text:

AUG 14, 1998

Mr. Eugene J. Secor                   Ref. No.  98-0224
EHS/Transportation Specialist
H.B. Fuller Automotive Company
31601 Research Park Drive
Madison Heights, Michigan 48071

Dear Mr. Secor:

This responds to your letter concerning shipping paper requirements of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you ask whether information concerning a shipment may be included on a shipping paper so that it can serve the dual purposes of a bill of lading and a packing list.

The HMR do not specify a particular format for shipping papers.  Rather, Subpart C of Part 172 sets forth the information that must be included on shipping papers and the order in which that information must appear.  The “mock-up” shipping document that you enclosed with your letter may be used as a shipping paper provided the requirements of Subpart C are met.

In this regard, we note that your “mock-up” does not include hazardous materials shipping descriptions.  For shipments of hazardous materials, the required shipping description means the basic description required by § 172.202, and additional description information required by § 172.203.  The basic description, consisting of the proper shipping name for the material as identified in § 172.101 of the Hazardous Material Table, the hazard class, the identification number and the packing group, if any, must be shown in sequence with no additional information interspersed.  Additional information, such as that required by § 172.203, or other additional information concerning the hazardous material must be placed after the basic description on a shipping paper, except that a technical name or chemical group name for a generic description may follow the proper shipping name.  The only information allowed to be placed before the basic description is quantity shipped, and the type of packaging and destination marks (see § 172.201(a)(2)(iii), § 172.201(a)(4) and § 172.202(c)).  Thus, you may include packing slip data applicable to a hazardous materials shipment on a shipping paper, but that information must be shown after the required shipping description. 

As you develop your shipping documents, you should also be aware of requirements for including a shipper’s certification on the shipping paper (see § 172.204).  In addition, most shipments of hazardous materials must be accompanied by emergency response information, including an emergency response telephone number (see Subpart G of Part 172).

I hope this information is helpful.  If you have further questions, please do not hesitate to contact this office.

Sincerely,

Thomas G. Allan
Senior Transportation Regulations Specialist
Office of Hazardous Materials Standards

172.202

Regulation Sections