Interpretation Response #00-0186 ([Oakite Products, Inc.] [Mr. Barry L. Dance])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Oakite Products, Inc.
Individual Name: Mr. Barry L. Dance
Location State: MI Country: US
View the Interpretation Document
Response text:
September 6, 2000
Mr. Barry L. Dance No. 00-0186
Oakite Products, Inc.
13177 Huron River Drive
Romulus, MI 48174
Dear Mr. Dance:
This is in response to your letter of June 14, 2000, concerning the Proper shipping description and markings for hazardous material packages according to the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically you ask if the shipping description on the shipping paper must be identical to the marking on the package if optional text is allowed in the shipping description. You present the following example where the shipping paper description is "Corrosive Liquids, Toxic, N.O.S. (Chromic Acid, Sulphuric Acid) 8, UN2922, PG II" and the marking on the package is "Corrosive Liquids, Toxic, N.O.S. (Contains Chromic Acid, Sulphuric Acid, Phosphoric Acid) 8, UN2922, PG II."
There is no requirement that the technical name text be identical on the package marking and shipping paper. However, it is recommended that the hazardous material description on the shipping paper and package marking be identical to minimize potential confusion by transporters and enforcement personnel. The requirements in ' 172.203(k) allow for optional text, such as the word "contains" or listing additional constituents beyond the required two which contribute to the hazard the material exhibits. Section 172.301 (a) and (b) require the shipping name, with technical names according to §172.203(k), and identification number be marked on a package.
I hope this satisfies your request.
Sincerely,
Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards
172.201
Regulation Sections
| Section | Subject |
|---|---|
| 172.201 | Preparation and retention of shipping papers |