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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 #11-0127 ([Veolia Environmental Services] [Ms. Jennifer Eberle])

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

Interpretation Response Details

Response Publish Date:

Company Name: Veolia Environmental Services

Individual Name: Ms. Jennifer Eberle

Location State: NJ Country: US

View the Interpretation Document

Response text:

September 8, 2011



Ms. Jennifer Eberle

Manager, Transportation Compliance

Veolia Environmental Services

1 Eden Lane

Flanders, NJ 07836

Reference No. 11-0127

Dear Ms. Eberle:

This is in response to your May 26, 2011 letter concerning the display of the "ORM-D" hazard class on a shipping paper for a "Consumer commodity." Specifically, you ask if it is permissible to omit the hyphen between the letters "m" and "d" under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).

The answer is no. Although the HMR permit a proper shipping name to appear on a shipping paper without punctuation marks (see § 172.101(c), it provides no such relief for the display of a hazard class.

For your information, please note that the HMR is phasing out use of the ORM-D hazard class and it will no longer be permitted to be used in domestic transportation after December 31, 2013 (see 76 FR 3308, 1/19/2011, Docket No. PHMSA-2009-0126 (HM-215K)). Various sections of the HMR will implement new limited quantity provisions in its place that will establish a standardized system for national and international multimodal transportation. Under this new system, consumer commodities will have the same provisions and requirements for international and national transportation as the approach for deminimis quantities, and excepted quantities, and will promote compliance, efficiency and consistent training and lower costs after implementation.

I hope this satisfies your request.


T. Glenn Foster

Chief, Regulatory Review and Reinvention Branch

Standards and Rulemaking Division


Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table