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Interpretation Response #05-0136 ([Onyx Environmental Services, L.L.C.] [Ms. Jennifer Eberle])

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

Interpretation Response Details

Response Publish Date:

Company Name: Onyx Environmental Services, L.L.C.

Individual Name: Ms. Jennifer Eberle

Location State: NJ Country: US

View the Interpretation Document

Response text:

Jul 27, 2005


Ms. Jennifer Eberle                     Reference No. 05-0136
Onyx Environmental Services, L.L.C.
1705 Route 46 West, Unit #2
Ledgewood, NJ 07852

Dear Ms. Eberle:

This responds to your June 2, 2005 letter requesting clarification on shipping paper requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask for clarification on what is meant by “distinctively tabbed” in §

The requirements of § 177.817(e)(1) are intended to ensure that shipping papers are readily available and easily identifiable in the event of an inspection or en1ergency. A hazardous materials shipping paper must be clearly identifiable, if carried with other shipping papers or other papers of any kind, with distinctive tabbing or by having it appear first in a stack of documents and papers. The definition of “táb” in Webster’s Unabridged Dictionary is “a slight flap, tag or strip, forming an appendage...” It is the opinion of this Office that a paperclip or binder clip does not conform to the requirements of § 177.8 17(e)(1). However, a flap, tag or strip, or a hazard warning label would be an acceptable method of tabbing if it is positioned to extend beyond the edge of the shipping paper. The tabbing should be of sufficient durability that it will not tear or become detached during the course of transportation.

I hope this answers your inquiry.



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


Regulation Sections

Section Subject
177.817 Shipping papers