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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 #11-0043 ([International Vessel Operators Dangerous Goods Association] [Mr. John V. Currie])

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

Interpretation Response Details

Response Publish Date:

Company Name: International Vessel Operators Dangerous Goods Association

Individual Name: Mr. John V. Currie

Location State: NY Country: US

View the Interpretation Document

Response text:

March 28, 2011



Mr. John V. Currie


International Vessel Operators

Dangerous Goods Association

10 Hunter Brook Lane

Queensbury, NY 12804

Ref. No.: 11-0043

Dear Mr. Currie:

This responds to your February 17, 2011 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to shipping papers. As required by § 173.166(c), for approved air bag inflators, air bag modules, or seat-belt pretensioners, the shipping paper must include the EX number or product code in association with the basic shipping description. Specifically, you ask whether multiple EX numbers or product codes corresponding to various approved airbag modules may be displayed in association with a single proper shipping name and basic description (e.g. UN3268, Air bag modules, 9, III).

Yes, a shipping paper describing multiple air bag modules packaged together in the same package or freight container described by the same UN number, proper shipping name, hazard class, and packing group may display multiple EX numbers or product codes in association with a single basic description. EX numbers or product codes, associated with a different proper shipping name (e.g. seat-belt pretensioners or air bag inflators) must be described separately.

I hope this answers your inquiry. If you need additional assistance, please contact the Standards and Rulemaking Division.


Ben Supko

Acting Chief, Standards Development Branch

Standards and Rulemaking Division


Regulation Sections

Section Subject
173.166 Safety devices