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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #06-0156 ([FedEx Express] [Mr. Thomas J. Leech, III])

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

Interpretation Response Details

Response Publish Date:

Company Name: FedEx Express

Individual Name: Mr. Thomas J. Leech, III

Location State: TN Country: US

View the Interpretation Document

Response text:

Jul 31, 2006


Mr. Thomas J. Leech, III                 Reference No. 06-0156
Dangerous Goods Administration
FedEx Express
3670 Hacks Cross Rd.
Building G, 2 Floor
Memphis, TN 38 125-9900

Dear Mr. Leech;

This is in response to your letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) pertaining to the Hazardous Material Incident Report Form (DOT F 5800.1). You asked for clarification of Item 27 of the form regarding the appropriate figures to be entered for “Package Capacity” and “Amount in the Package.” Specifically, you ask whether “Package Capacity” refers to the design capacity of the outer package or the capacity of the inner packages, and if there is no capacity marking on the package, whether the amount of hazardous materials should be entered in place of the package capacity. You also asked whether the actual number of inner packages being shipped should be entered, or whether the entry should represent the capacity of the outer package.

As described in the “Guide for Preparing Hazardous Materials Incident Reports,” under “Instructions” on page 6 and “Packaging Information” on page 2 of Part III, you must indicate the capacity, amount of hazardous material, total number of packages, and number of packages that failed. This information should be entered for both inner and outer packages. Item #27 contains separate columns for inner packages and outer packages and all information should be entered in the appropriate columns and categories.

“Package Capacity” means the amount a package is capable of containing when full, regardless of the actual number of inner packages (with respect to combination packages) or amount of hazardous materials (with respect to inner packages). The capacity should
be indicated by units of measurement (liter, gallons, pounds, etc.). If the packages do not
have the marked capacity, you must make that determination for purposes of completing the incident report form. For a non-bulk, IBC, or non-specification packaging, Item 26B would be filled in if the marking is incomplete, destroyed, or unknown.

“Amount in Package” means the actual amount of hazardous materials in the package. For example, if a shipment contains five outer packages with each outer package containing four inner packages of six liters of hazardous material, the entry for the outer package column would be 24 liters, and the entry for inner package column would be six liters.

“Number in Shipment” means the total number of packages, both failed and unaffected, that were being transported. Continuing with the above example, the entry for the outer package column would be five and the entry for the inner package column would be 20.

“Number Failed” means the number of packages that were damaged or otherwise failed. Still using the above example, if two inner packages in the same outer package failed, the entry for the outer package column would be one and the entry for the inner package column would be two.

I hope this information is helpful. Please contact this office should you have additional questions.



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


Regulation Sections

Section Subject
171.16 Detailed hazardous materials incident reports