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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.



John A. Gale

Chief, Standards Development

Office of Hazardous Materials Standards

171.8, 172.101(c)

Regulation Sections

Section Subject
171.8 Definitions and abbreviations
172.101 Purpose and use of hazardous materials table