Interpretation Response #08-0065 ([ERM, Inc.] [Mr. Mark Yannett])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: ERM, Inc.
Individual Name: Mr. Mark Yannett
Location State: WI Country: US
View the Interpretation Document
Response text:
April 25, 2008
Mr. Mark Yannett
Senior Project Manager
Strategic Services & Product Sustainability
ERM, Inc.
700 W. Virginia Street, Suite 601
Milwaukee, WI 53204
Ref. No. 08-0065
Dear Mr. Yannett:
This is in response to your March 10, 2008 request for clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to shipping papers.
In your letter, you state that you client transports "Sulfuric acid with not more than 51% acid," (UN2796) by highway with other materials not subject to the HMR. You ask whether the requirements specified under § 172.201(a)(1)(ii) and (iii) apply if the shipping description of the hazardous material is the first entry on the shipping paper as required by § 172.201(a)(1)(i).
The answer is no. Section 172.201(a)(1) authorizes hazardous and non- hazardous materials to be described on the same shipping paper provided that the hazardous material description entry:
(1) is entered first (§ 172.201(a)(1)(i)); or
(2) is entered in a color that clearly contrasts with any description on the shipping paper of a non-hazardous material § 172.201(a)(1)(ii)); or
(3) is identified by the entry of an "X" placed before the proper shipping name in a column captioned "HM." The "X" may be replaced by "RQ," is appropriate (§ 172.201(a)(1)(iii)).
You also ask whether there are any load-specific conditions, such as a shipment in a
quantity requiring a placard, that would require an "X" in the HM Column as specified in
§ 172.201(a)(1)(iii). There are no load-specific conditions that would require an "X" in the HM Column as specified in § 172.201(a)(1)(iii).
I hope this information is helpful.
Sincerely,
John A. Gale,
Chief, Standards Development
Office of Hazardous Materials Standards
17.201(a)(1)(i)
Regulation Sections
| Section | Subject |
|---|---|
| 172.201 | Preparation and retention of shipping papers |