Interpretation Response #03-0273 ([Texas Propane Gas Association] [Ms. Jackie R. Richards])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Texas Propane Gas Association
Individual Name: Ms. Jackie R. Richards
Location State: TX Country: US
View the Interpretation Document
Response text:
Jan 7, 2004
Ms. Jackie R. Richards Reference No. 03-0273
Texas Propane Gas Association
8408 N. IH-35
Austin, TX 78753
Dear Ms. Richards:
This is in response to your letter dated October 27, 2003 and subsequent telephone conversation with a member of my staff. Specifically, you request clarification on the shipping paper retention requirements under § 172.201(e). Your questions are paraphrased and answered as follows:
Ql. Does the shipping, paper retention requirement only apply to the initial carrier of the hazardous material?
Al. No. Each shipper or carrier who provides or receives a shipping paper is subject to the shipping paper retention requirements.
Q2. May a carrier meet the shipping paper retention requirements if they use a permanent shipping paper?
A2. Yes. Section 172.201(e) allows the carrier to retain a single copy of the shipping paper, instead of a copy for each shipment made, if the carrier also retains a record of each shipment made.
Q3. Would a “deliver ticket” meet the shipping paper retention requirement as a record of each shipment made under a permanent shipping paper?
A3. Yes, if each “deliver ticket” includes the following information: shipping name, identification number, quantity transported, and date of shipment.
Q4. How would a propane dealer meet the shipping paper retention requirement if they deliver the same hazardous material without change, but do not file a permanent shipping paper?
A4. The propane dealer must retain a copy of each shipping paper, or an electronic image thereof.
I hope this satisfies your request.
Sincerely,
John A. Gale
Transportation Regulations Specialist
Office of Hazardous Materials Standards
172.201
Regulation Sections
| Section | Subject |
|---|---|
| 172.201 | Preparation and retention of shipping papers |