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Interpretation Response #05-0151 ([RWE NUKEM Corporation] [Mr. Stanley M. Hodges, Jr.])

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

Interpretation Response Details

Response Publish Date:

Company Name: RWE NUKEM Corporation

Individual Name: Mr. Stanley M. Hodges, Jr.

Location State: SC Country: US

View the Interpretation Document

Response text:

Jun 29, 2005


Mr. Stanley M. Hodges, Jr.                       Reference No.: 05-0151
Senior Project Manager
RWE NUKEM Corporation
3800 Fernandina Road Suite 200
Columbia SC, 29210-3854

Dear Mr. Hodges:

This is in response to your June 22, 2005 letter regarding multi-page shipping papers under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your questions are paraphrased and answered as follows:

Q1.      Must a one page shipping paper bear the notation ‘Page 1 of 1”?

Al.        No. In accordance with § 172.201(c), the first page of a multi-page shipping paper must bear a notation specifying the total number of pages. Single page shipping papers are not subject to this requirement.

Q2.      Are page numbers required on documents that must be provided “with” shipping papers?

A2.      No. When the HMR require information be “on” a shipping paper and the information necessitates a continuation page, § 172.201(c) applies. When the HMR require information to be “with” a shipping paper or be provided in a document “other than a shipping paper” (e.g., exclusive use instructions or emergency response information), page numbers are not required on the additional documents.

Q3.      If emergency response information is provided in an attachment to a shipping paper must it be numbered?

A3.      See A2.

Q4.      If a shipping paper makes reference to attached documents must the attached documents be numbered?

A4.      No. Attached documents, even when required under the HMR, are not part of the shipping paper and are therefore not subject to § 172.201(c)

I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.



Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards

172.6052(b), 173.427

Regulation Sections

Section Subject
173.427 Transport requirements for low specific activity (LSA) Class 7 (radioactive) material and surface contaminated objects (SCO)