Interpretation Response #05-0277 ([Onyx Environmental Services, LLC] [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, LLC
Individual Name: Ms. Jennifer Eberle
Location State: NJ Country: US
View the Interpretation Document
Response text:
Dec 5, 2005
Ms. Jennifer Eberle Reference No. 05-0277
Manager, Transportation Compliance
Onyx Environmental Services, LLC
1705 Route 46 West, Unit #2
Ledgewood, NJ 07852
Dear Ms. Eberle:
This is in response to your letter dated October 24, 2005, and subsequent telephone conversation with a member of my staff requesting clarification of the proper shipping name requirements of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you inquired about the proper placement of italicized words within a shipping description.
Italicized information may be utilized in addition to the proper shipping name (§ 172.101(c)(2)). The overall orientation of additional information is optional; however, the preferred sequence for the proper shipping name is established by the Hazardous Material Table (HMT) ( 172.10l(c)(4)). In the example you provide, a shipper is preparing adhesives for transportation and includes italicized information on the shipping paper. In that case both "Adhesives, containing a flammable liquid, 3, UN 1133, PG I" or "Adhesives, 3, UN 1133, PG I, containing a flammable liquid" are acceptable proper shipping descriptions. The first description utilizes the sequence found in the HMT and is preferred.
I hope this satisfies your request.
Sincerely,
John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards
171.8, 172.101(c)