Interpretation Response #04-0156 ([Action Unlimited Resources, Inc] [Mr. M.A. Pinto])

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

Interpretation Response Details

Response Publish Date: 07/21/2004

Company Name: Action Unlimited Resources, Inc

Individual Name: Mr. M.A. Pinto

Location State: DE Country: US

View the Interpretation Document

Response text:

Jul 21, 2004

Mr. M.A. Pinto                Reference No. 04-0156
Action Unlimited Resources, Inc.
230 Quigley Blvd.
New Castle, Delaware 19720-4106

Dear Mr. Pinto:

This responds to your May 21, 2004, letter requesting clarification on the retention of shipping papers under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if you may combine hazardous and non-hazardous materials in a single shipping document and if you may retain copies on a computer.

The answer to both questions is yes. Section 172.201(a)(1) authorizes hazardous and non- hazardous materials to be described on the same shipping paper provided that the hazardous materials: (1) the hazardous material is entered first; (2) entered in a color that clearly contrasts with any description on the shipping paper of a non-hazardous material; or (3) identified by the entry of an “X” placed before the proper shipping name in a column captioned “HM.” The “X” may be replaced by “RQ”, if appropriate. You may retain your shipping papers with entries for both hazardous and non-hazardous materials electronically, if a hard copy is provided to an authorized representative upon request. A separate document is not required; however, a separate document, such as a daily inventory/shipping receipt, may be retained when using a “permanent” shipping paper, as provided under § 172.201(e).

I hope this answers your inquiry.

Sincerely,

John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards

172.201

Regulation Sections