USA Banner

Official US Government Icon

Official websites use .gov
A .gov website belongs to an official government organization in the United States.

Secure Site Icon

Secure .gov websites use HTTPS
A lock ( ) or https:// means you’ve safely connected to the .gov website. Share sensitive information only on official, secure websites.

U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #13-0214 ([3M] [Mr. Todd Strobe])

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

Interpretation Response Details

Response Publish Date:

Company Name: 3M

Individual Name: Mr. Todd Strobe

Location State: MN Country: US

View the Interpretation Document

Response text:

December 19, 2013

Mr. Todd Strobel
Regulatory Compliance Specialist
3M
3M Center Building 225-4S-18
St. Paul, MN  55144

Ref. No.: 13-0214

Dear Mr. Strobel:

This is in response to your email dated November 8, 2013, requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) relating to shipments offered in accordance with Canada's Transport of Dangerous Goods Regulations (TDG Regulations).  Your questions are paraphrased and answered as follows:

Q1-  Must a shipping paper provided for hazardous materials originating in Canada, and offered by motor carrier or rail, conform to all applicable requirements of subpart C of part 171 of the HMR?

A1- Yes.  Shipments originating from Canada and offered for transportation by motor carrier or rail in accordance with the TDG Regulations are authorized for transport by § 171.12(a)(1) provided the applicable requirements in §§ 171.22 and 171.23 are met.  

Q2-  Is it necessary for shipping papers for shipments originating in Canada to indicate the number and type of packages?

A2-  - Shipments originating from Canada and offered for transportation by motor carrier or rail in accordance with the TDG Regulations are authorized for transport by § 171.12(a)(1) provided the applicable requirements in §§ 171.22 and 171.23 are met. TDG Regulation 3.5 (1)(e) requires a number of small means of containment for all dangerous goods that require a label to be displayed on them to be indicated on shipping papers, but no requirement equivalent to the § 172.202(a)(7) HMR requirement to indicate a type of package exists in the TDG Regulations. There is no requirement in subpart A or subpart C for shipping papers accompanying shipments made in accordance with TDG regulations to comply with § 172.202.  Furthermore, section 171.12(a)(1) specifically excepts shipments transported in accordance with the TDG Regulations from parts 172, 173, and 178 of subchapter C of the HMR (except as otherwise provided in subpart A and subpart C of 171).

I trust this information is helpful.  If you have further questions, please do not hesitate to contact this office.

Sincerely,

Duane A. Pfund
International Standards Coordinator
Standards and Rulemaking Division

171.12, 171.22, 171.23

Regulation Sections

Section Subject
171.12 North American Shipments
171.22 Authorization and conditions for the use of international standards and regulations
171.23 Requirements for specific materials and packagings transported under the ICAO Technical Instructions, IMDG Code, Transport Canada TDG Regulations, or the IAEA Regulations