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Interpretation Response #08-0134 ([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:

October 31, 2008

Mr. Chris W. Gibson

EHS&R Manager

Hawkins, Inc.

3100 East Hennepin Avenue

Minneapolis, MN 55413

Reference No. 08-0134

Dear Mr. Gibson:

This is in response to your letter asking for clarification of requirements for a multi-page shipping paper under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You state your company receives orders for hazardous materials at different times from the same customers and creates a new shipping paper for each order. As a result, your drivers sometimes deliver several orders to the same customer with different shipping documents. You ask us to assume the emergency response telephone numbers, shipper certification statements and signatures, and net and/or gross weights of the materials are identical. We paraphrased your questions and answered them in the order provided. We apologize for the delay in responding and regret any inconvenience this may have caused.

Q1. Must a multi-page shipping paper comply with § 172.201(c)?

A1. Yes. Under § 172.201(c), a shipping paper may consist of more than one continuation page if each page in the shipping paper is numbered and the first page has a notation specifying the total number of pages, e.g., "Page 1 of 4 pages." However, individual shipping papers are not considered a multi-page shipping document under the HMR.

Q2. Must a multi-page shipping paper have only one signed shipper certification statement under

§ 172.204?

A2. Yes, only one signed certification statement is required for a multi-page shipping paper. This signed certification can appear on the first or top page of the multi-page shipping paper. Also, please note placing the signature anywhere on the same page as the certification statement constitutes signing the certification.

I hope this information satisfies your request.


Hattie L. Mitchell

Chief, Regulatory Review and Reinvention

Office of Hazardous Materials Standards

172.201(c), 172.204

Regulation Sections

Section Subject
172.201 Preparation and retention of shipping papers
172.204 Shipper's certification