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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 #11-0071 ([EnviroServe] [Mr. Larry Steigerwald])

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

Interpretation Response Details

Response Publish Date:

Company Name: EnviroServe

Individual Name: Mr. Larry Steigerwald

Location State: OH Country: US

View the Interpretation Document

Response text:

June 22, 2011



Mr. Larry Steigerwald


5502 Schaaf Road

Cleveland, OH 44131

Reference No. 11-0071

Dear Mr. Steigerwald:

This is in response to your e-mail requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to shipping paper requirements. Specifically, you ask for clarification of § 172.201(a)(4) and whether the HMR allows an emergency response guidebook (ERG) number and an Environmental Protection Agency (EPA) waste stream number specific to the material to be added to shipping papers following the proper shipping description.

Section 172.201(a)(4) allows for a shipping paper to contain additional information concerning the material being transported provided the information is not inconsistent with the required description. In addition, unless otherwise permitted or required by the HMR, additional information must be placed after the basic description required by §172.202(a) of the HMR. Therefore, additional information may be entered on the shipping paper under these conditions.

Please note that § 172.203(c)(1) provides that for a hazardous waste, the waste code (e.g., D001), if appropriate, may be used to identify the hazardous substance. If the EPA waste code identifies a hazardous substance, it must be in parentheses in association with the basic description. For example, UN3077, Environmentally hazardous substance, solid, n.o.s., (D008, asbestos), 9, PG III may be used. With respect to the ERG number, although it is not required on the shipping paper, if a carrier uses the ERG to fulfill the emergency response information requirements, the proper shipping name and the UN identification number are acceptable to cross reference the correct entry in the ERG.

I hope this information is helpful. Please contact this office should you have additional questions.


T. Glenn Foster

Chief, Regulatory Review and Reinvention

Standards and Rulemaking Division

172.201, 172.203

Regulation Sections

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