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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 #15-0015 ([FedEx Express] [Mr. Marvin Sudduth])

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

Interpretation Response Details

Response Publish Date:

Company Name: FedEx Express

Individual Name: Mr. Marvin Sudduth

Location State: TN Country: US

View the Interpretation Document

Response text:

July 20, 2015

Mr. Marvin Sudduth
FedEx Express
3670 Hacks Cross Rd.
Building G, 2nd Floor
Memphis, TN 38125

Ref. No.: 15-0015

Dear Mr. Sudduth:

This responds to your January 20, 2015 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) with regard to the carrier functions regarding salvage packaging.  Specifically, you ask whether a carrier who utilizes a salvage drum as prescribed in § 173.3(c) in order to continue transportation of a damaged package containing hazardous materials to its destination or to return the package to a shipper is permitted to cross out the packaging type and net quantity on the original shipping papers and insert the new packaging type (e.g. steel drum) and estimated net quantity.  You further ask PHMSA to confirm that if the carrier is allowed to make changes to the shipping papers no other changes to the shipping papers are required.  

Section 173.3(c)(5) states “the shipper shall prepare shipping papers in accordance with subpart C of part 172 of this subchapter”.  In a situation where salvage packaging is required to transport hazardous materials for repackaging or disposal § 173.3(c)(5) requires that new shipping papers be prepared to appropriately identify the shipment.  If the carrier elects to perform these functions the carrier assumes responsibility for ensuring these functions are correctly performed.   

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


Duane A. Pfund
International Standards Coordinator
Standards and Rulemaking Division
173.3(c). 173.3(c)(5)

Regulation Sections

Section Subject
173.3 Packaging and exceptions
173.3 Packaging and exceptions