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Interpretation Response #07-0039

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

Interpretation Response Details

Response Publish Date: 06-28-2007
Company Name: Hapag-Lloyd (America) Inc.    Individual Name: Mr. Robert F. Ahlborn
Location state: NJ    Country: US

View the Interpretation Document

Response text:

Jun 28, 2007


Mr. Robert F. Ahlborn                  Reference No. 07-0039
Manager, Hazardous Materials
Hapag-Lloyd (America) Inc.
399 Hoes Lane
Piscataway, NJ 08854

Dear Mr. Ahlborn:

This responds to your electronic mail dated February 2, 2007, requesting the validity of an interpretation issued to you by this office on May 22, 1995, concerning differences in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) and the International Dangerous Goods Code (IMDG Code) with regard to documentation requirements. You again ask whether a shipping paper certification is necessary for import shipments of hazardous materials at marine terminals in U.S. ports awaiting subsequent transportation.

The answer to your question is yes. The dangerous goods list requirement in paragraph 5.4.3 of Part 5 of the IMDG Code and in § 176.30 of the HMR apply only to hazardous materials loaded on board a ship. Once a container is unloaded from a vessel to a marine terminal and is awaiting subsequent transportation or devanning, there is no requirement other than the emergency response information requirement specified in § 172.602(c) (2). Using a dangerous goods list to serve as the emergency response document is permissible when the dangerous goods list meets the requirements in § 172.602(c) (2).

When subsequent transportation is provided and the container is loaded on a truck or rail car, the document required is a shipping paper. Use of a dangerous goods list to serve as the shipping paper is permissible when the dangerous goods list meets all shipping paper requirements of Part 5 of the IMDG Code or 49 CFR Part 172, Subparts C and G (shipping papers, including certification and emergency response, respectively).

I trust this satisfies your inquiry. Please contact us if we can be of further assistance.



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

172.602 (c)(2), 176.30

Regulation Sections

Section Subject
§ 176.30 Dangerous cargo manifest