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Interpretation Response #02-0147 ([DuPont Company] [Randolph Martin])

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

Interpretation Response Details

Response Publish Date:

Company Name: DuPont Company

Individual Name: Randolph Martin

Location State: DE Country: US

View the Interpretation Document

Response text:

June 28, 2002

Mr. Randolph Martin                  Reference No: 02-0147
Hazardous Materials Distribution Consultant
DuPont Company
1007 Market Street, Room D-5100
Wilmington, DE 19898

Dear Mr. Martin:

This is in response to your April 19, 2002 email requesting clarification of the shipping paper requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you asked if you are required to use only LIN specification packaging type names in meeting the requirements for identifying the type packages on shipping papers.  The examples you referred to were pails, cans, cartons.

In accordance with § 172.202 (5)(c), the total quantity of the material covered by one description must appear before or after, or both before and after, the description required and authorized by this subpart.  The type of packaging and destination marks may be entered in any appropriate manner before or after the basic description.  Abbreviations may be used to express units of measurement and types of packagings.

In the International Maritime Dangerous Goods (IMDG) Code paragraph 5.4.1.1.1.5 requires the dangerous goods transport document contain information on the number and kind of packages and the total quantity of dangerous goods covered by the description (by volume or mass, and in the case of goods of class 1 by the net explosives mass of the contents).

Although both the HMR and IMDG Code use the terms "type" and "kind" to describe packagings, no specific terminology or criteria is identified.  Therefore, any appropriate terminology for packagings, such as pails, barrels, cans or cartons are acceptable.

I hope this information is helpful.  Please contact us if you require additional assistance

Sincerely,

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

172.202

Regulation Sections

Section Subject
172.202 Description of hazardous material on shipping papers