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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #04-0231 ([Environmental Resource Center] [Ms. Pretlo V. Knight])

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

Interpretation Response Details

Response Publish Date:

Company Name: Environmental Resource Center

Individual Name: Ms. Pretlo V. Knight

Location State: NC Country: US

View the Interpretation Document

Response text:

Nov 29, 2004


Ms. Pretlo V. Knight                 Reference No. 04-0231

Senior Consultant

Environmental Resource Center

101 Center Pointe Drive

Cary, North Carolina 27513

Dear Ms. Knight:

This responds to your September 7, 2004 letter requesting clarification on marking and shipping paper requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-18 D). Specifically, you ask for an explanation of the marking and shipping paper requirements for a hazardous materials shipment containing two or more inner packagings of different but compatible hazardous materials packed together in the same outer package.

You describe: the following scenario: a package contains the following inner packagings- a 1-gallon glass bottle of benzene, a 1-gallon glass bottle of acetone, a 1-gallon glass bottle of ethanol, and t 4-ounce plastic bottle of elemental mercury. It is your understanding that the outer package must bear the proper shipping names and identification numbers for each hazardous material in the inner packagings. It is also your understanding that the shipping paper must include a separate basic description for each hazardous material in the inner packagings.

Your understanding is correct. Section 173.24(e) authorizes the shipment of a mixed content of hazardous materials in the same outer package provided the hazardous materials are compatible and will not react dangerously with each other. The outer package must be marked with the proper shipping name and identification number and labeled in accordance with Subpart E of Part 172 for each hazardous material contained therein.

In addition, each hazardous material packaged in the outer package must also be properly described on the shipping paper in accordance with Subpart C of Part 172, including the number and type of packagings.

I hope this answers your inquiry.



John A.  Gale

Chief, Standards Development

Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.24 General requirements for packagings and packages