Interpretation Response #06-0053
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Apr 11, 2006
Ms. Debbie Hape Reference No. 06-0053
Global Transportation Compliance Specialist
PGM Global Logistics
1855 Shelby Oaks Drive North
Memphis, TN 38134
Dear Ms. Hape:
This is in response to your e-mail dated March 2, 2006 regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 100-180) to shipping papers.
You state that the current Voluntary Interindustry Commerce Standards (VICS) standard bill of lading uses the abbreviation “DOT” instead of “Department of Transportation,” in the shipper’s certification statement required on shipping papers under § 172.204. You ask whether use of this abbreviation is acceptable under the HMR. You also state that the “Weight” column of the current VICS standard bill of lading does not contain the term “lbs.” You ask if this omission is acceptable under the HMR.
The certification statement specified in § 172.204(a)(1) must be written as specified and may not be modified. Therefore, use of the abbreviation “DOT” in lieu of “Department of Transportation” in the shipper’s certification statement is unacceptable.
Section 172.202(a)(5) requires the total quantity of hazardous materials covered by the shipping description to be indicated (by mass or volume, or by activity for Class 7 materials) and must include an indication of the applicable unit of measurement. There is no requirement in the HMR that restricts units of measurement to “lbs.” Therefore, the term “lbs” is not required as a pre-populated field on shipping papers. However, you must provide an indication of a unit of measurement as part of the shipping description.
Please do not hesitate to contact us for other inquiries concerning the Hazardous Materials Regulations.
John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards
|§ 172.204||Shipper's certification|