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Interpretation Response #07-0213 ([Hawkins, Inc.] [Mr. Chris W. Gibson ])

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

Interpretation Response Details

Response Publish Date:

Company Name: Hawkins, Inc.

Individual Name: Mr. Chris W. Gibson 

Location State: MN Country: US

View the Interpretation Document

Response text:

Nov 19, 2007


Mr. Chris W. Gibson                             Ref. No.: 07-0213

EHS&R Manager

Hawkins, Inc.

3100 East Hennepin Avenue

Minneapolis, MN  55413

Dear Mr. Gibson:

This is in response to your November 2, 2007 letter requesting clarification of the transition compliance date for the shipping description sequence in § 171.14(e) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). 

Your questions are paraphrased and answered as follows:

Q1: Does the transition compliance date of January 1, 2013 apply to domestic and/or international shipments of hazardous materials?

A1: The transition compliance date in § 171.14(e) generally applies to domestic shipments of hazardous materials.  The sequence change in § 172.202(b) was incorporated to align the HMR with international requirements.  Most international regulations that are authorized for use by the HMR already require the new sequence to be used.  For background on the shipping description sequence please review Docket HM-215I (71 FR 78596; December 29, 2006).  As provided by the December 29, 2006 final rule and in § 172.202(b) of the HMR, beginning January 1, 2013, the HMR will require hazardous materials shipments to be identified on the shipping paper in the sequence of identification number, proper shipping name, hazard class or division number, and packing group.      

Q2: Is the proper shipping name and identification number marking in § 172.301(a) required to be in the same sequence as the shipping description?

A2: No.  Section 172.301(a) does not require a specific sequence for marking the proper shipping name and identification number on a package.

I hope this information is helpful. Please contact us if you require additional assistance.



John A. Gale

Chief, Standards Development

Office of Hazardous Materials Standards

File: 171.14 (e), 172.301(a)

Regulation Sections

Section Subject
172.301 General marking requirements for non-bulk packagings