Interpretation Response #15-0087 ([Con-way Freight] [Ms. Marie Easley-Cook])

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

Interpretation Response Details

Response Publish Date: 06/11/2015

Company Name: Con-way Freight

Individual Name: Ms. Marie Easley-Cook

Location State: MI Country: US

View the Interpretation Document

Response text:

June 11, 2015

Ms. Marie Easley-Cook
Hazardous Materials Administrator
Con-way Freight
2211 Old Earhart Road, Suite 100
Ann Arbor, MI 48105

Reference No. 15-0087

Dear Ms. Easley Cook:

This is in response to your letter dated April 27, 2015 regarding the shipper's certification prescribed in § 172.204 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether a shipper's certification may be signed using only the initials of the person certifying the shipment.

In accordance with 49 CFR Part 172 Subpart C, each person who offers a hazardous material for transportation must certify that the material is offered for transportation by printing (manually or mechanically) on the shipping paper the certification contained in § 172.204(a)(1) or the certification (declaration) containing the language in § 172.204(a)(2). Further, in accordance with § 172.204(d), the certification must be legibly signed by a principal, officer, partner, or employee of the shipper or his agent; and may be signed manually, by typewriter, or by other mechanical means. The HMR do not define the term signature; therefore, the signature requirement prescribed in § 172.204(d) may be satisfied by the use of initials provided the initials are traceable to the person certifying the hazardous materials for transportation.

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

Sincerely,

Duane Pfund
International Standards Coordinator
Standards and Rulemaking Division

172.204(a)(1), 172.204(a)(2), 172.204(d), 172.204

Regulation Sections