Interpretation Response #12-0255 ([North America Regional Trainer] [Ms. Susan Numbers])

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

Interpretation Response Details

Response Publish Date: 12/20/2012

Company Name: North America Regional Trainer

Individual Name: Ms. Susan Numbers

Location State: OH Country: US

View the Interpretation Document

Response text:

December 20, 2012

Ms. Susan Numbers
North America Regional Trainer
Expeditors-Cleveland
6950 Engle Road
Suite XX
Middleburg Heights, OH 44130

Ref. No. 12-0255

Dear Ms. Number:

This responds to your November 5, 2012 request for clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the basic shipping description of a hazardous material on a shipping paper. Specifically, in your incoming letter you provide examples of shipping papers are requests clarification if these are acceptable formats. Your questions are paraphrased and answered below.

Q1. If a shipping paper uses column headings to describe the format and order of the required basic shipping description as specified in §§ 172.202(a)(1)-(4) and the heading for the first column is titled "UN No", do the letters "UN" still need to be included in the line item entry in front of the 4 digits?

A1. Yes, in accordance with § 172.202(a)(1) the identification number prescribed for the material as shown in column (4) if the §172.101 table must be displayed. This would include the letters "UN" as part of the UN Identification Number assigned to that hazardous material.

Q2. You provide an example of a shipping paper and ask if the horizontal row format and row headings used in the example would be acceptable under §§ 172.202(a)(1)-(4)?

A2. No, in accordance with § 172.202(b) the basic shipping description specified in §§ 172.202(a)(1)-(4) must be shown in sequence with no additional information interspersed. While a horizontal format is not prohibited, the inclusion of row headings intersperses additional information in the basic shipping sequence and therefore is prohibited.

Q3. Would the addition of a colon ":" or "#"between the letters "UN" and the 4 digits of the UN number be considered interspersed information (i.e. UN:1564 or UN#1564) and therefore prohibited.

A3. Yes, the addition of a colon ":" or "#"between the letters "UN" and the 4 digits of the UN number is prohibited. In accordance with § 172.202(b) the basic shipping description specified in §§ 172.202(a)(1)-(4) must be shown in sequence with no additional information (i.e. ":" or "#") interspersed.

Q4. When using a shipping paper use a horizontal row format, is the shipping paper required to include "UN" in conjunction with the four digit number (i.e. "3077") in the basic shipping description if the row header makes a reference to the "UN" (i.e. UN #, UN No., or UN)?

A4: See A2. Furthermore, the shipping paper is required to include "UN" in conjunction with the four digit number (i.e. "3077").

I hope this answers your inquiry. If you need further assistance, please contact this office at (202) 366-8553.

Sincerely,

Robert Benedict
Chief, Standards Development Branch
Standards and Rulemaking Division

172.202

Regulation Sections