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Interpretation Response #04-0188 ([Safety & Compliance Associates, Inc.] [Mike Lopez, JD])

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

Interpretation Response Details

Response Publish Date:

Company Name: Safety & Compliance Associates, Inc.

Individual Name: Mike Lopez, JD

Location State: AL Country: US

View the Interpretation Document

Response text:

Oct 13, 2004


Mike Lopez, JD                 Reference No. 04-0188
Safety & Compliance Associates, Inc.
P.O. Box 48
Trussville, AL 35173

Dear Mr. Lopez:

This is in response to your July 19, 2004 letter concerning the shipping paper requirements of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your questions are paraphrased and answered as follows:

Q1:      Despite the example provided in § 172.202(a) (2) (iii), which does not include parentheses around the subsidiary hazard class or division number, must the subsidiary hazard class or division number appear in parentheses on the shipping paper?

Al:        Except for combustible liquids, the subsidiary hazard class(es) or subsidiary division number(s) must be entered in parentheses immediately following the primary hazard class or division number. The examples in § 172.202 (a) (2) (iii) should be corrected by placing parentheses around the subsidiary class (es) and division number(s). This error will be addressed in a future rulemaking.

Q2:      Does the shipper have the option of using the subsidiary hazard class or division number (e.g., (5) or (5.1) for an oxidizer) on a shipping paper?

A2:       No. The shipper must use the subsidiary hazard class or division number as appropriate for the material being shipped (e.g., the subsidiary hazard for an oxidizer must appear as (5.1)).
Voluntary compliance with the requirement to enter subsidiary hazards on shipping papers was authorized by Docket HM-215E (68 FR 44992) as of July 31, 2003. However, the mandatory compliance date is October 1, 2005 (171.14(d) (7)).



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


Regulation Sections

Section Subject
172.202 Description of hazardous material on shipping papers