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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 #13-0018 ([Association of American Railroads] [Mr. Matthew Forister])

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

Interpretation Response Details

Response Publish Date:

Company Name: Association of American Railroads

Individual Name: Mr. Matthew Forister

Location State: DC Country: US

View the Interpretation Document

Response text:

May 23, 2013


Mr. Matthew Forister
Assistant Director, Tank Car/Hazmat Safety
Association of American Railroads
425 Third Street, S.W., Suite 1000
Washington, DC 20024

Reference No.  13-0018

Dear Mr. Forister:

This is in response to your e-mail requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the description of a hazardous material on a shipping paper.  Specifically, you ask whether the words “non-odorized” or “not-odorized,” as required by § 172.203(p), may be placed within the basic description, in association with the basic description, or both, when offering for transportation non-odorized liquefied petroleum gas (LPG).  You reference a previous letter of interpretation, Reference Number 12-0207, applicable to this scenario, and ask whether the words “non-odorized” or “not-odorized” may be placed anywhere in the basic description, including immediately before the proper shipping name, and offered for transportation internationally.  

Our response in letter of interpretation, Reference Number 12-0207, remains valid.  As prescribed in § 172.203(p), the word “non-odorized” or “not-odorized” must be included in association with the proper shipping description (i.e., basic description) on a shipping paper when non-odorized liquefied petroleum gas is offered for transportation.  As you correctly point out in your letter, “In association with refers to the placement of required additional entries on the shipping paper.  Usually placed after the complete description for a hazardous material.  May be in any format, as long as it is clearly part of the entry.”

Except as provided otherwise in subpart C of part 172, the basic description specified in
§ 172.202, paragraphs (a)(1), (2), (3), and (4), must be shown in sequence with no additional information interspersed.  Further, this requirement is consistent with recognized international standards.  Although international standards require that additional required information be placed after the basic description on a transport document, unless specified otherwise, the HMR do not.  Therefore, for domestic shipments of non-odorized LPG, it is permissible to place the words “non-odorized” or “not-odorized” in association with the basic description either before or after the basic description and not within it.  For international shipments originating in the U.S., the words “non-odorized” or “not-odorized” should follow the basic description and not be placed within it.  

I hope this information is helpful.  Please contact this office should you have additional questions.


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

172.203, 172.202

Regulation Sections

Section Subject
172.202 Description of hazardous material on shipping papers
172.203 Additional description requirements