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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 #14-0222 ([Enterprise Products] [Mr. Christopher Scavone])

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

Interpretation Response Details

Response Publish Date:

Company Name: Enterprise Products

Individual Name: Mr. Christopher Scavone

Location State: TX Country: US

View the Interpretation Document

Response text:

March 25, 2015

Mr. Christopher Scavone
Enterprise Products
1100 Louisiana St.
Houston, TX 77002-5227

Reference No. 14-0222

Dear Mr. Scavone:

This is in response to your e-mail requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the description of a hazardous material on a shipping paper. Specifically, you ask if the odorant information for liquefied petroleum gas (LPG) is correctly indicated on your shipping papers. The shipping papers you provided include scenarios for both odorized and non-odorized shipments by highway and rail.

The shipping papers you have provided for non-odorized LPG, would not be compliant with § 172.203(p) which requires that the word “non-odorized” or "not-odorized" must be included in association with the proper shipping description (i.e., basic description) on a shipping paper when non-odorized liquefied petroleum gas is offered for transportation. Although your shipping papers do indicate the material is "non-odorized," it is not provided in association with the basic description. As prescribed in § 172.202(b) the basic description must be shown in sequence with no additional information interspersed. For domestic shipments of non-odorized LPG, the words “non-odorized” or “not-odorized” may be placed in association with the basic description either immediately before or after the basic description.

The type of tank used for highway transport is not described in your incoming letter. Please note that in accordance with § 172.203(h)(2), for LPG transported in a MC 330 or MC 331 cargo tank by highway, the word "NONCORROSIVE" or "NONCOR" must follow the basic description to indicate the suitability for shipping "Noncorrosive" liquefied petroleum gas in a cargo tank made of quenched and tempered steel, or the words “NOT FOR Q and T TANKS” follow the basic description for grades of liquefied petroleum gas other than "Noncorrosive".

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


Duane Pfund
International Standards Coordinator
Standards and Rulemaking Division

172.203(p), 172.202(b), 172.203(h)(2)

Regulation Sections

Section Subject
172.202 Description of hazardous material on shipping papers
172.203 Additional description requirements