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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 #13-0033 ([Dangerous Good of America   ] [Mr. Fred A Romero])

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

Interpretation Response Details

Response Publish Date:

Company Name: Dangerous Good of America   

Individual Name: Mr. Fred A Romero

Location State: FL Country: US

View the Interpretation Document

Response text:

April 16, 2013



Mr. Fred A Romero
Dangerous Good of America                                 
1651 NW 68th St., Cargo Building 706
Suite 211
Miami, FL 33152-0487

Reference No. 13-0033

Dear Mr. Romero:

This is in response to your January 11, 2013 letter to the Pipeline and Hazardous Materials Safety Administration (PHMSA) requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180), applicable to the use of the letter "G" on shipping papers.  In your letter, you note that § 172.202(a)(6)(vi) states that for items where "No Limit" is shown in Column (9A) (Quantity limitations for passenger aircraft/rail) or (9B) (Quantity limitations for cargo aircraft only) of the Hazardous Materials Table (HMT), the quantity shown must be the net mass or volume of the material.  For articles ( e.g., UN2800 and UN3166), the quantity must be the gross mass, followed by the letter "G."  You also note that in the International Civil Aviation Organization Technical Instructions (ICAO TI), as well as the International Air Transport Association Dangerous Goods Regulations (IATA DGR), the letter "G" is no longer required on the shipping paper or the shippers declaration.  You ask if you must include the gross mass followed by the letter "G" as required by the HMR, or may you exclude the letter "G" on the shipping paper as indicated in the ICAO TI and IATA regulations.

The provisions of §§ 171.23 and 171.24 of the HMR authorize the use of the ICAO TI for packaging, marking, labeling, classifying, and describing hazardous materials which are transported by air and by motor vehicle either before or after being transported by air.  Therefore, if your shipment is being transported in accordance with the ICAO TI as authorized by the HMR, the letter "G" would not be required on the shipping paper.

I hope this satisfies your request.


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

171.23, 171.24, 172.202

Regulation Sections

Section Subject
171.23 Requirements for specific materials and packagings transported under the ICAO Technical Instructions, IMDG Code, Transport Canada TDG Regulations, or the IAEA Regulations
171.24 Additional requirements for the use of the ICAO Technical Instructions
172.202 Description of hazardous material on shipping papers