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Interpretation Response #05-0255 ([Totem Ocean Trailer Express, Inc.] [Ms. Nancy Airdasd])

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

Interpretation Response Details

Response Publish Date:

Company Name: Totem Ocean Trailer Express, Inc.

Individual Name: Ms. Nancy Airdasd

Location State: WA Country: US

View the Interpretation Document

Response text:

Dec 1, 2005


Ms. Nancy Aird                      Reference No. 05-0255
Totem Ocean Trailer Express, Inc.
P. 0. Box 4129
Federal Way, WA 98063-4129

Dear Ms. Aird:

This responds to your letter concerning the use of certain abbreviations in the shipping paper description of a hazardous material under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).
Your questions are paraphrased and answered as follows:

Q1.      Are the only allowed definitions and abbreviations found in § 171.8?

Al.        The answer is no. In addition to § 171.8, definitions and abbreviations are found throughout the HMR. For example, abbreviations that may be used in a shipping paper description are found in Subpart B of Part 172 of the HMR.

Q2.      May the following commonly recognized words and abbreviations be used to describe the type of packing on a shipping paper or dangerous cargo manifest for vessel transportation? Barrel - bbl, can - cn, case - cs, carton - ctn, package - pkg, pail or tote.

A2.      Neither the HMR nor the IMDG Code specify terminology or criteria to describe the type or kind of packaging; hence, the terms are acceptable. Section 172.202 (a)(5) of the HMR authorizes abbreviations to indicate the type of packaging. Dangerous goods being transported by vessel must be prepared in accordance with the International Maritime Dangerous Goods (IMDG) Code. The IMDG Code is silent on the use of abbreviations to identify packaging type; however, the regulatory text reads “The number and kind (e.g., drum, box, etc.) shall also be indicated.” In the case of international shipments it may be prudent to avoid abbreviations that may be unfamiliar to non-English speaking persons.

Q3.      Section 171.8 does not define the term “barrel.” May “barrel” be used to describe a packaging type?

A3.      Yes. See A2. Also, the term “wooden barrel” is defined in § 171.8 of the HM.

I trust this satisfies your request.



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

171.8, 172.202(a)(5)

Regulation Sections

Section Subject
171.8 Definitions and abbreviations
172.202 Description of hazardous material on shipping papers