Interpretation Response #13-0046 ([FedEx Freight, Inc.] [Ms. Sandra Richesin & Mr. Mike Brust])

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

Interpretation Response Details

Response Publish Date: 06/06/2013

Company Name: FedEx Freight, Inc.

Individual Name: Ms. Sandra Richesin & Mr. Mike Brust

Location State: AR Country: US

View the Interpretation Document

Response text:

June 6, 2013

Ms. Sandra Richesin
Safety Compliance Specialist
Mr. Mike Brust
Corporate Safety                            
FedEx Freight Inc.                                      
2200 Forward Drive                                      
P.O. Box 840                                               
Harrison, AR 72602-0840        

Reference No. 13-0046

Ms. Richesin and Mr. Brust:

This is in response to your e-mail requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR 171-180) applicable to shipping papers.  Specifically, you ask about the proper placement of the type of packaging (i.e.; “BOX”) on a shipping paper.  The format of the shipping paper as shown in your e-mail is as follows:

PCS     HM      DESCRIPTION                                       WGT/lbs
                       
1           X        BOX,UN2790,ACETIC ACID SOLUTION,8        26
                     PGII
 

You state that the word “BOX” is located in front (to the left) of the hazardous material basic description and ask whether this is in conformance with the requirements specified in  § 172.202, “Description of hazardous material on shipping papers.”

The number and type of packages must be indicated (for example, “1 box” or “8 fiberboard drums”) on a shipping paper (see §§ 172.202(a)(7) and 172.202(c)) either before or after the required basic description.  The number and type of packaging, total quantity shipped, and destination marks are the only entries permitted to precede the basic description, and may be repeated after the basic description.    

As the shipping paper appears in your e-mail, we observe a few items that may be problematic.  Although placed before the basic description, the word “BOX” appears to be under the column heading “Description,” and is separated from the number of boxes, “1,” which is placed under the column heading “PCS.”  Additionally, the placement of “PGII” appears to be placed after the weight (“26”).  The packing group should be directly following the hazard class.  

We suggest either moving the word “BOX” to the first column (PCS) next to the “1” under a column heading such as “Number and Type of Packages,” or moving column (PCS) so that it is above the word “BOX” and separated before or after the column heading “Description.”  Additionally, we suggest either moving “PGII” up to the line immediately following the hazard class (“8”) or inserting vertical lines and horizontal lines where necessary; in effect creating columns and delineating more clearly the authorized split between the description requirements.
 

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

Sincerely,

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

172.202

Regulation Sections