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Interpretation Response #09-0153 ([Layne Christensen Company Safety and Environmental Health Sciences] [Ms. Rhonda Heltzel])

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

Interpretation Response Details

Response Publish Date:

Company Name: Layne Christensen Company Safety and Environmental Health Sciences

Individual Name: Ms. Rhonda Heltzel

Location State: KS Country: US

View the Interpretation Document

Response text:

August 26, 2009

 

 

Ms. Rhonda Heltzel

Layne Christensen Company

Safety and Environmental Health Sciences

610 S. 38th Street

Kansas City, KS 66106

Ref. No.: 09-0153

Dear Mr. Heltzel:

This responds to your April 16, 2009 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) pertaining to the placement of number and type of packages on shipping papers.

You provide three examples of shipping descriptions in your letter and ask if the number and type of packages are in compliance with the shipping paper requirements of the HMR.

Except as otherwise provided by the HMR, the basic description on a shipping paper must be entered in sequence with no additional information interspersed (see § 172.202(b)). The number and type of packages must appear either before or after the basic description and any additional information must be entered after the basic description.

The examples you provided in your letter are depicted below along with our answers for each.

Example 1:

Answer 1: The number of packages is appropriately entered in column 1 before the basic description. However, the type of package is incorrectly entered in column 3 of the table after the proper shipping name and before the hazard class.

Example 2:

Answer 2: The number and type of packages are appropriately entered in column 1 before the basic description. However, the EX-number is incorrectly placed after the proper shipping name in column 3. The EX-number is additional information and must appear after the basic description required by § 172.202(a) (see § 172.201(a)(4)).

Example 3:

Answer 3: The number of packages is appropriately entered in column 1 before the basic description. However, the EX-number and type of package are incorrectly entered in column 3 after the proper shipping name.

The common problem with the three examples is the additional information and the type of package appear in association with the proper shipping name in column 3 without any visible marks or lines to separate that information from the proper shipping name. Therefore, the additional information is interspersed in the basic description.

Also note that until January 1, 2013 the basic description may be entered with the proper shipping name first followed by the hazard class, UN identification number, and packing group (e.g., Cyclobutyl chloroformate, 6.1, (8, 3), UN2744, PG II) or it may be entered with the UN identification number first, followed by the proper shipping name, hazard class, and

packing group (e.g. UN2744, Cyclobutyl chloroformate, 6.1, (8, 3), PG II). Effective January 1, 2013, the basic description must be entered with the UN identification number first.

I hope this information is helpful. If we can be of further assistance, please contact us.

Sincerely,

Charles Betts

Chief, Standards Development

Office of Hazardous Materials Standards

172.202, 172.201

Regulation Sections

Section Subject
172.201 Preparation and retention of shipping papers
172.202 Description of hazardous material on shipping papers