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Interpretation Response #11-0286 ([R+L Carriers, Inc.] [Mr. Gerald A. Krisa])

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

Interpretation Response Details

Response Publish Date:

Company Name: R+L Carriers, Inc.

Individual Name: Mr. Gerald A. Krisa

Location State: OH Country: US

View the Interpretation Document

Response text:

December 22, 2011



Mr. Gerald A. Krisa
Vice-President of Safety
R+L Carriers, Inc.
600 Gillam Road
Wilmington, OH 45177

Reference No. 11-0286

Dear Mr. Krisa:

This is in response to your November 8, 2011 e-mail requesting clarification on the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to pre-printed bills of lading, described herein as shipping papers. Specifically, you ask whether you may provide your company"s customers with pre-printed shipping papers that list the hazardous materials they commonly ship but not the quantity, package type, or weight and/or volume. You state the customers will complete this information when they offer your company their shipment for transportation.

The answer is yes. Provided the shipping paper complies with the applicable requirements of the HMR, the HMR do not prohibit the use of shipping papers pre-printed with one or more hazardous material proper shipping descriptions.

You also ask if an "X" may be placed in the "HM" column for the hazardous material shipping descriptions on the pre-printed shipping paper before giving it to the customers or if this field must be left blank until the material is actually being shipped. The HMR do not prohibit a pre-printed "X" from appearing in the HM column for hazardous materials that are not being shipped. The shipping paper requirement in § 172.201(a)(1)(iii) specifies that a shipping paper, containing both a regulated hazardous material and a non-regulated material, may identify the hazardous material by placing an "X" in a column captioned "HM," or replace the "X" with an "RQ," if appropriate. The hazardous materials being shipped may be identified by the shipper entering the number of packages in the column preceding the HM column and the weight in the column following the basic description (see § 172.202(a)(5), (a)(6), and (a)(7)). The absence of an entry in the quantity or weight column indicates that a material is not being shipped.


I hope this satisfies your request.




T. Glenn Foster
Chief, Regulatory Review and Reinvention
Standards and Rulemaking Division

172.201, 172.202

Regulation Sections

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