Interpretation Response #25-0090
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Public Utilities Commission
Individual Name: Tad Rumas
Location State: OH Country: US
View the Interpretation Document
Response text:
March 11, 2026
Mr. Tad Rumas
Public Utilities Commission
180 E Broad Street
Columbus, Ohio 43215
Reference No. 25-0090
Dear Mr. Rumas:
This letter is in response to your July 2, 2025 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to additional shipping paper description information for radioactive materials. It is your understanding that § 172.203(d) appears to indicate that all additional information (i.e., "entries") must immediately follow the basic description required by § 172.202. However, you note that § 172.203(d)(9)(ii) states that an "Exclusive Use Shipment" may be entered only once on the shipping paper in a clearly visible location" and § 172.203(d)(10) states that for the shipment of a package containing a highway route controlled quantity of Class 7 (radioactive) materials the words "Highway route controlled quantity" or "HRCQ" must be entered in association with the basic description, while §§ 172.203(d)(1)–(d)(8) provide no such specificity.
We have paraphrased and answered your questions as follows:
Q1. Does the phrase "[t]he description for a shipment of a Class 7 (radioactive) material must include the following additional entries" in § 172.203(d) indicate that the additional information (i.e., entries) must immediately follow the basic description (to include horizontal or vertical format) only?
A1. No. As stated in § 172.203(d), the phrase indicates that the information required by this paragraph, unless specifically instructed otherwise, is considered additional description information and must be a part of the hazardous material description for the radioactive material, but not necessarily immediately before or after the basic description.
Q2. With respect to the requirement for a highway route controlled quantity package in § 172.203(d)(10), does the phrase "in association with" indicate that the additional information must immediately follow the basic description (to include horizontal or vertical format) only?
A2. No. The phrase "in association with the basic description" means placing additional information as part of the basic description either immediately before, after, or interspersed with the basic description. See, for example, the instructions for including a technical name in § 172.203(k) and the examples provided.
Q3. Based on the answers to Q1 and Q2, would it be permissible for information required by § 172.203(d)(1)–(d)(8) to be in another location on the shipping paper?
A3. No. Section 172.203(d) specifies that the information must be included as part of the hazardous material description for the radioactive material.
Q4. Regarding the requirement for a highway route controlled quantity package in § 172.203(d)(10), based on the answers to Q1 and Q2, when is information no longer considered "in association with" the basic description?
A4. See answer A2.
Q5. Based on the answers to Q1 and Q2, when are entries considered "not included" with the basic description?
A5. Regarding the requirement in § 172.203(d) for the shipment description to include the following additional entries, the term "entries" means information. As stated in answer A1, the additional information, as appropriate, must be included in the hazardous material description, not the basic description (as spelled out in § 172.202(b)).
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division