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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.



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


Regulation Sections

Section Subject
172.204 Shipper's certification