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Interpretation Response #14-0107 ([PCS Sales (USA), Inc] [Mr. Tracey G. Smith])

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

Interpretation Response Details

Response Publish Date:

Company Name: PCS Sales (USA), Inc

Individual Name: Mr. Tracey G. Smith

Location State: IL Country: US

View the Interpretation Document

Response text:

July 24, 2014

Mr. Tracey G. Smith
Manager, Regulatory Compliance
PCS Sales (USA), Inc.
110 Skokie Boulevard, Suite 400
Northbrook, IL 60062

Ref No.: 14-0107

Dear Mr. Smith:

This responds to your May 27, 2014 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) with regard to the basic shipping description on shipping papers when there is no packing group shown in the §172.101 Hazardous Materials Table (HMT).  Specifically you ask, if there is a packing group assigned to UN2426, Ammonium nitrate, liquid, and if there is not, how the basic description on the shipping paper should read.

There is no packing group associated with UN2426, Ammonium nitrate, liquid.  The only authorized packaging in the HMR for Ammonium nitrate, liquid, is set forth in §173.243, which prescribes bulk packaging for certain high hazard liquids and dual hazard materials that pose a moderate hazard.  Section 172.202(a)(4) requires that the packing group in Roman numerals, as designated for the hazardous material in Column (5) of the §172.101 HMT, must be entered on the shipping paper, but states that entries that are not assigned a packing group are excepted from this requirement.  Therefore, the basic shipping description for Ammonium nitrate, liquid would be “UN2426, Ammonium nitrate, liquid, 5.1.”

I hope this information is helpful.  If you have any more questions, please do not hesitate to contact this office.


Robert Benedict
Chief, Standards Development
Standards and Rulemaking Division

172.101, 173.243, 172.202(a)(4)


Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table
172.202 Description of hazardous material on shipping papers
173.243 Bulk packaging for certain high hazard liquids and dual hazard materials which pose a moderate hazard