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Interpretation Response #07-0196 ([The Shepherd Chemical Company] [Mr. Bayard Pelsor])

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

Interpretation Response Details

Response Publish Date:

Company Name: The Shepherd Chemical Company

Individual Name: Mr. Bayard Pelsor

Location State: OH Country: US

View the Interpretation Document

Response text:

Nov 19, 2007

Mr. Bayard Pelsor

EHS Manager

The Shepherd Chemical Company

4900 Beech Street

Norwood, Ohio 45212

Ref. No. 07-0196

Dear Mr. Pelsor:

This is in response to your e-mail asking whether the abbreviation "TT" is acceptable under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) for representing a cargo tank when indicating the packaging type on shipping papers.  You point out that the U.S. Environmental Protection Agency (EPA) authorizes the abbreviation for hazardous waste manifests.  In a follow-up telephone conversation with a member of my staff you asked whether "TT" would be an acceptable abbreviation on shipping papers for hazardous materials that do not require a hazardous waste manifest.

The answer is yes.  The abbreviation "TT" is a commonly accepted and recognizable abbreviation for cargo tanks

(tank trucks) and, thus, may be used to indicate a shipment"s packaging type on shipping papers in accordance with § 172.202(a)(6) of the HMR.

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

Sincerely,

Hattie L. Mitchell

Chief, Regulatory Review and Reinvention

Office of Hazardous Materials Standards

172.202(a)(7)

Regulation Sections