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Interpretation Response #01-0246 ([Occidental Chemical Company] [Ms. Elaine Palazzo])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: Occidental Chemical Company

Individual Name: Ms. Elaine Palazzo

Location State: TX Country: US

View the Interpretation Document

Response text:

October 15, 2001


Ms. Elaine Palazzo                            Reference No. 01-0246
Regulatory Compliance Specialist
Occidental Chemical Company
5005; LBJ Freeway
Dallas, TX 75244-6119

Dear Ms.  Palazzo:

This is in response to your letter dated September 24, 2001, requesting clarification on the placement of the
 total quantity on a shipping paper.  Specifically, you ask whether additional information may be placed
between the basic description required by § 172.202(a)(1), (2), (3), and (4) and the total quantity required
 by  § 172.202(a)(5).

The answer is yes.  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.  Additional information concerning the material must be placed after the basic description (§ 172.201 (a)(4)).  When the total quantity appears after the basic description, additional information may be placed before or after the total quantity.

I hope this satisfies your request.



Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
172.202 Description of hazardous material on shipping papers