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Interpretation Response #07-0221 ([R+L Carriers Shared Services, LLC] [Ms. Tina S. Breezley])

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

Interpretation Response Details

Response Publish Date:

Company Name: R+L Carriers Shared Services, LLC

Individual Name: Ms. Tina S. Breezley

Location State: OH Country: US

View the Interpretation Document

Response text:

March 14, 2008

Ms. Tina S. Breezley

Hazardous Materials & Training Manager

R+L Carriers Shared Services, LLC

P.O. Box 271

Wilmington, OH 45177

Reference No. 07-0221

Dear Ms. Breezley:

This is in response to your recent e-mail and telephone conversations with members of my staff asking how to properly describe the type of package for a hazardous material on a shipping paper under § 172.202(a)(6) of the Hazardous Materials Regulations (49 CFR Parts 171-180). You state your company transports "UN 1263, Paint, 3 (flammable liquid), PG III" by motor vehicle for different shippers throughout the United States in non-specification fiberboard boxes that contain four inner non-specification plastic pails. You state these packages comply with the HMR but vary in design and are made by different manufacturers. You also state in the past this agency instructed you to describe the type of package as "pails" instead of "boxes."

What constitutes a package under the HMR depends on the particular packaging provision that is being used. Based on the information you provided, the package is a combination package, consisting of a strong outer packaging with one or more inner packagings as provided by § 173.150. The outer and inner packagings, used together, meet the minimum prescribed HMR requirements. In this case, the package must be described by its outer packaging as "box" or "boxes." See the definitions of "combination packaging," "package or outside package," and "single packaging" in § 171.8.

We apologize for any misinformation you may have received earlier from our agency regarding this matter and any inconvenience. Also please note that we revised § 172.202(a)(6) and relocated it to § 172.202(a)(7) effective January 1, 2007. In addition, we permitted delayed compliance with former § 172.202(a)(6) until January 1, 2008. See Docket No. PHMSA-06-25476 (HM-215I, 71 FR 78596, 12/29/06).

I hope this satisfies your request. Please contact this office if you have further questions.


Hattie L. Mitchell

Chief, Regulatory Review and Reinvention

Office of Hazardous Materials Standards

172.202(a) 173.150

Regulation Sections

Section Subject
171.8 Definitions and abbreviations
172.202 Description of hazardous material on shipping papers