Interpretation Response #05-0005 ([Tyco Healthcare/Mallinckrod] [Ms. April Chance])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Tyco Healthcare/Mallinckrod
Individual Name: Ms. April Chance
Location State: MO Country: US
View the Interpretation Document
Response text:
Feb 28, 2005
Ms. April Chance Reference No. 05-0005
Manager, Radiological Affairs
Tyco Healthcare/Mallinckrodt
675 McDonald Blvd
Hazzelwood, MO 63042
Dear Ms. Chance:
This is in response to your letter dated January 5, 2005, regarding the shipper’s certification prescribed in § 172.204 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you request clarification on the signature requirement in § 172.204(d). Your questions are paraphrased and answered below.
Q1: Is it acceptable to use a rubber stamped name with an adjacent signature or initials to fulfill the signature requirements in § 172.204(d)?
Al: The answer is yes. The certification must be legibly signed by a principal, officer, partner, or employee of the shipper or his agent; and (2) may be legibly signed manually, by typewriter, or by other mechanical means. The use of a rubber stamp to produce a signature would satisfy this requirement.
Q2: Is it acceptable to use a signature page that cross-references printed names with signatures, which would remain at the facility (i.e. would not accompany the shipping paper), to fulfill the shipping paper requirements in § 172.204(d)?
A2: The answer is no. By providing a certified shipping paper the person who offers a hazardous material for transportation certifies that the material is offered for transportation in accordance with the HMR. The required shipping paper must contain the shipping description, a certification statement (see § 172.204(a)(1) or (a)(2)), and an authorized signature (see Al).
I hope this satisfies your request.
Sincerely,
John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards
172.204(d)
Regulation Sections
| Section | Subject |
|---|---|
| 172.204 | Shipper's certification |