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Interpretation Response #13-0109 ([Veolia ES Technical Solutions, L.L.C.] [Ms. Jennifer Eberle])

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

Interpretation Response Details

Response Publish Date:

Company Name: Veolia ES Technical Solutions, L.L.C.

Individual Name: Ms. Jennifer Eberle

Location State: NJ Country: US

View the Interpretation Document

Response text:

July 12, 2013


Ms. Jennifer Eberle
Manager, Transportation Compliance
Veolia ES Technical Solutions, L.L.C.
1 Eden Lane
Flanders, NJ  07836

Reference No. 13-0109

Dear Ms. Eberle:

This is in response to your May 17, 2013 letter requesting clarification on the use of the symbol “%” for the word “percent” under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you ask if this symbol may be used to replace the word “percent” in the proper shipping name you provided as an example: “Nitric acid other than red fuming, with more than 70 percent nitric acid.”

The answer is yes.  Under § 172.101(c)(1), words in a proper shipping name listed in Column 2 of the Hazardous Materials Table (§ 172.101) may alternatively be spelled in the same manner as they appear in the International Civil Aviation Organization’s Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICAO Technical Instructions) or the International Maritime Dangerous Goods Code (IMDG Code).  Under the ICAO Technical Instructions and IMDG Code, the proper shipping name for nitric acid with a concentration of 70 percent or more is “Nitric acid, other than red fuming, with more than 70% nitric acid.”  This alternative spelling may be used regardless of the mode of transportation used.  

I hope this satisfies your request.


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


Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table