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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 #15-0084 ([United States Air Force] [Mr. Jeremy McCauley])

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

Interpretation Response Details

Response Publish Date:

Company Name: United States Air Force

Individual Name: Mr. Jeremy McCauley

Location State: HI Country: US

View the Interpretation Document

Response text:

August 12, 2015

Mr. Jeremy D. McCauley
United States Air Force
240 McChord Street
Hickam AFB, HI 96853

Ref. No. 15-0084

Dear Mr. McCauley:

This is a response to your April 27, 2015 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to documentation accompanying hazardous materials shipments. In your email, you describe a scenario whereby a domestic shipment of "UN1005, Ammonia, Anhydrous" is shipped under a competent authority approval (CA2001120001) and a Department of Transportation Special Permit (DOT-SP 15837) as a Division 2.3 poisonous gas material. On each piece of documentation (e.g., shipping paper, competent authority approval, and DOT Special Permit), the subsidiary hazard Class 8 corrosive is not listed. Your questions are paraphrased and answered below.

Q1. For a shipment of "UN1005, Ammonia, Anhydrous," must the subsidiary hazard Class 8 be considered when authorizing documentation (i.e., a competent authority approval and DOT Special Permit) does not list the subsidiary hazard and it is offered for transportation using the international primary hazard classification of Division 2.3?.

A1. The answer is yes. The subsidiary risk of this material is applicable. When transported using the international classification of Division 2.3, "UN1005, Ammonia, Anhydrous" is required to be labeled with the subsidiary hazard Class 8 in accordance with § 172.402(g)(3). Consequently, in accordance with § 172.202(a)(3), the subsidiary hazard must be represented on a hazardous materials shipping paper when the subsidiary hazard warrants labeling. A subsidiary hazard might not be indicated on a competent authority approval or DOT Special Permit as these documents merely reference the materials for which the corresponding document is authorized for use. Additionally, relief from the HMR is not provided except as stated by the authorizing documents (i.e., a DOT Special Permit or competent authority approval). Therefore, unless the authorizing documentation explicitly notes the subsidiary hazard is not to be considered, the subsidiary hazard Class 8 applies to the shipment.

Q2. Is the Department of the Navy Certificate of Equivalency (COE) NA-07-850 required to accompany future shipments of this material?

A2. The answer is no. CA2001120001 and DOT-SP 15837 replace COE NA-07-850 and both sets of documentation would not be required to accompany the shipment. Only a copy of the competent authority approval and the DOT Special Permit would be required as outlined in the conditions for use of those documents.

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



Dirk Der Kinderenbr
Acting Chief, Standards Development
Standards and Rulemaking Division

172.402(g)(3), 172.202(a)(3)

Regulation Sections

Section Subject
172.202 Description of hazardous material on shipping papers
172.402 Additional labeling requirements