Interpretation Response #08-0015 ([Fed Ex Freight] [Ms. Sandra Richesin])

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

Interpretation Response Details

Response Publish Date: 02/21/2008

Company Name: Fed Ex Freight

Individual Name: Ms. Sandra Richesin

Location State: AR Country: US

View the Interpretation Document

Response text:

February 21, 2008

Ms. Sandra Richesin

Fed Ex Freight

P.O. Box 840

Harrison, AR 72602-0840

Ref. No. 08-0015

Dear Ms. Richesin:

This is in response to your letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) pertaining to the shipper"s certification statement on shipping papers. You ask two questions pertaining to the signature that is required for the statement. The questions are paraphrased and answered below.

Q1. A shipping paper includes a shipper"s certification statement as required by

§ 172.204. If the shipping paper has one designated place for a signature, is any location on the shipping paper acceptable for the signature that is required for the statement?

A1. Location of the signature anywhere on the same page as the certification statement constitutes signing of the statement, provided the signature is not specifically assigned to a statement not required by the HMR.

Q2. A shipping paper includes two designated places for signatures. One is specific to the shipper"s certification statement and the other is located elsewhere on the shipping paper. The former is not signed; the latter is signed. Does this meet the requirements under the HMR for the shipper"s certification signature?

A2. You did not submit an example of the shipping paper in question. Because the certification statement in this case includes a signature line specifically assigned to the certification statement, leaving it unsigned may be confusing and may cause frustration of the shipment of hazardous materials. Although the HMR do not specify a location of the signature on a shipping paper, reasonable care should be taken to format a shipping paper that does not cause confusion.

I hope this information is helpful. If you have additional questions, please do not hesitate to contact this office.

Sincerely,

Hattie L. Mitchell, Chief

Regulatory Review and Reinvention

Office of Hazardous Materials Standards

§ 172.204

Regulation Sections