Interpretation Response #02-0085 ([Brenntag Great Lakes, LLC] [Michael R. Schick])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Brenntag Great Lakes, LLC
Individual Name: Michael R. Schick
Location State: WI Country: US
View the Interpretation Document
Response text:
May 31,2002
Mr. Michael R. Schick Reference No. 02-0085
Regional Manager of Quality,
Health, & Safety
Brenntag Great Lakes, LLC
P.O. Box 444
Butler, WI 53007-0444
Dear Mr. Schick:
This is in response to your March 20, 2002 letter regarding shipping paper requirements. Specifically, you ask if the additional information contained in the quantity ordered, quantity shipped, back order and packaging columns of your shipping paper is in compliance with the requirements contained in § 172.201(a)(4) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).
The answer is no. Section 172.201(a)(4) states that the shipping paper may contain additional information concerning the material provided the information is not inconsistent with the shipping description and it is placed after the basic description required by § 172.202(a). Certain notations such as &quo;RQ&quo; and a technical name or chemical group name for a generic description may appear before the proper shipping name (§ 172.203). Other information authorized before the basic description is the total quantity, and the type of packaging and destination marks (see § 172.201 (a)(1)(iii), § 172.201(a)(4) and § 172.202(c)). For example, shipping papers that are designed in a column format may have the quantity shipped and type of packaging, e.g., "19 drums" entered before the basic description. Other information must be entered on the shipping paper after the basic description. In your shipping paper the quantity ordered and back order columns are presented prior to (to the left of) the column containing the basic description; and therefore, is not in compliance with the HMR.
I hope this satisfies your request.
Sincerely,
John A. Gale
Transportation Regulations Specialist
Office of Hazardous Materials Standards
172.201
Regulation Sections
| Section | Subject |
|---|---|
| 172.201 | Preparation and retention of shipping papers |