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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #08-0018 ([Airgas-SAFECOR] [Mr. John Anderson])

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

Interpretation Response Details

Response Publish Date:

Company Name: Airgas-SAFECOR

Individual Name: Mr. John Anderson

Location State: WY Country: US

View the Interpretation Document

Response text:

March 4, 2008


Mr. John Anderson


P.O. Box 20067

Cheyenne, WY 82003

Reference No. 08-0018

Dear Mr. Anderson:

This is in response to our January 15, 2008 telephone conversation and your e-mail concerning the entry "Chlorodifluoromethane or Refrigerant Gas R 22, 2.2 (non-flammable gas), UN 1018" appearing in the § 172.101 Hazardous Materials Table (HMT; 172.101) of the Hazardous Materials Regulations (HMR). The HMT lists "Chlorodifluoromethane" and "Refrigerant Gas R 22" in Roman type. You state your company receives the material from different vendors in packages marked with either proper shipping name. You ask if your company"s shipping paper may display both proper shipping names or if it must display only one.

When one proper shipping name includes alternative wording choices that appear in Roman type in a sequence and are separated by the word "or" in italics, such as "Articles, pressurized pneumatic or hydraulic containing non-flammable gas," it is the intent of § 172.101(c)(2) that Roman type wording choice that appropriately describes the material, e.g., pneumatic or hydraulic, must be used. However, in your scenario, both Roman type names describe the same material. Therefore, it would be permissible to show the proper shipping name as "Chlorodifluoromethane or Refrigerant gas R22."

I hope this satisfies your request. If you have any further questions, please contact this office at (202) 366-8553.


Hattie L. Mitchell

Chief, Regulatory Review and Reinvention

Office of Hazardous Materials Standards


Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table