Interpretation Response #11-0179 ([Hapag-Lloyd (America) Inc.] [Mr. Matt Krynski Director])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Hapag-Lloyd (America) Inc.
Individual Name: Mr. Matt Krynski Director
Location State: NJ Country: US
View the Interpretation Document
Response text:
September 14, 2011
Mr. Matt Krynski
Director, Dangerous Goods and Security
Hapag-Lloyd (America) Inc.
399 Hoes Lane
Piscataway, NJ 08854
Ref. No.: 11-0179
Dear Mr. Krynski:
This responds to your August 2, 2011 letter seeking clarification of the shipping paper requirements of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if § 172.202 allows "hazard class 3" to be listed in the description for combustible liquids on shipping papers. You provide the following example: "NA 1993, Combustible liquid, n.o.s. (technical name), 3, PG III."
The answer to your question is no. Instead of a numerical hazard class, "Combustible liquid" is the hazard class. This is demonstrated in the listing for "Combustible liquids, n.o.s." in the Hazardous Materials Table, Column 3 that shows the applicable Hazard class or Division as "Comb liq." Further, § 172.101(d)(4) requires that each reference to a Class 3 material is modified to read "Combustible liquid" when that material is reclassified in accordance with §173.150(e) or (f) of this subchapter or has a flash point above 60 °C (140 °F) but below 93 °C (200 °F).
I hope this answers your inquiry. If you need additional assistance, please contact the Standards and Rulemaking Division at (202) 366-8553.
Sincerely,
Ben Supko
Acting Chief, Standards Development
Standards and Rulemaking Division
172.202, 172.101, 173.150