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Interpretation Response #02-0234 ([HB Fuller Company] [Gene Secor])

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

Interpretation Response Details

Response Publish Date:

Company Name: HB Fuller Company

Individual Name: Gene Secor

Location State: MI Country: US

View the Interpretation Document

Response text:

May 7, 2003

Mr. Gene Secor                 Reference No. 02-0234
HB Fuller Company
31601 Research Park Drive
Madison Heights, MI 48071

Dear Mr. Secor:

This responds to your letter requesting clarification of the documentation requirements under the International Air Transport Association's Dangerous Goods Regulations (IATA DGR).  Specifically, you ask for this office’s opinion of the IATA DGR requirement to annotate the ”Name and Title of Signatory” on the shipper's declaration for dangerous goods and ask whether ”Shipper” or ”Shipping Clerk” are acceptable titles under of the IATA DGR.  I apologize for the delay in responding.

The regulations recognized by the Department of Transportation and authorized in 49 CFR 171.11 as an alternative to compliance with 49 CFR requirements are the International Civil Aviation Organization's Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICAO TI).  Under 5; of the ICAO TI, there is no requirement to annotate a "Title” on a shipping paper in association with the certification.  The ICAO TI only require that the certification be signed and dated by the shipper.  Therefore, we suggest that you contact IATA directly regarding this matter at (514) 390-6770.

Please contact us if we can be of further assistance.


Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
172.204 Shipper's certification