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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.


Ben Supko

Acting Chief, Standards Development

Standards and Rulemaking Division

172.202, 172.101, 173.150

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table
172.202 Description of hazardous material on shipping papers
173.153 Exceptions for Division 6.1 (poisonous materials)