Interpretation Response #10-0076 ([Hyundai America Shipping Agency, Inc.] [Mr. Herb Giles])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Hyundai America Shipping Agency, Inc.
Individual Name: Mr. Herb Giles
Location State: TX Country: US
View the Interpretation Document
Response text:
May 27, 2010
Mr. Herb Giles
Manager, Hazardous Materials
Hyundai America Shipping Agency, Inc.
7701 Las Colinas Ridge, Suite 400
Irving, TX 75063
Ref. No. 10-0076
Dear Mr. Giles:
This responds to your March 31, 2010 letter regarding shipping paper description requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask for clarification of the requirement in § 172.202(b) that the basic description on a shipping paper must be shown in sequence with "no additional information interspersed."
Your letter includes copies of shipping papers with additional wording interspersed in the basic description. The basic descriptions include category titles for the component parts of the basic description interspersed within the basic description sequence such as "UN Number," "Proper Shipping Name," "Packaging Group," and "Hazard Class." You ask whether the formats used on the shipping papers comply with § 172.202(b).
The answer is no. Except for provisions that allow for additional information to be included in the basic description sequence, no additional information may be interspersed in the basic description. For example, § 172.202(a)(3)(i) allows the words "Class" or "Division" to precede the hazard class or division number(s) in the basic description sequence and § 172.202(d) allows the technical or chemical group name to be entered in parentheses between the proper shipping name and hazard class in the basic description sequence. Otherwise, no additional information such as category titles may be interspersed in the basic description sequence.
I hope this information is helpful. If you have further questions, please contact this office.
Sincerely,
Charles E. Betts
Chief, Standards Development
Office of Hazardous Materials Standards
172.202
Regulation Sections
| Section | Subject |
|---|---|
| 172.202 | Description of hazardous material on shipping papers |