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Interpretation Response #15-0121 ([The Lane Construction Corporation] [Ms. Michele A. Jacobs])

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

Interpretation Response Details

Response Publish Date:

Company Name: The Lane Construction Corporation

Individual Name: Ms. Michele A. Jacobs

Location State: NC Country: US

View the Interpretation Document

Response text:

September 15, 2015

Ms. Michele A. Jacobs
Corporate Safety and Fleet Manager
The Lane Construction Corporation
8205 Wilkinson Blvd.
Charlotte, NC 28214

Ref. No. 15-0121

Dear Ms. Jacobs:

This responds to your email of June 16, 2015 requesting clarification on shipping paper requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your questions have been paraphrased and answered as follows:

Q1. Must a shipping paper that describes a shipment of diesel fuel in a cargo tank motor vehicle show the quantity transported in a specific unit of measurement such as gallons?

A1. No. Under § 172.202(a)(5)(iii)(A), the HMR allow the total quantity of hazmat transported in a bulk package, such as in your scenario, to be described on the shipping paper by indicating the number and type of bulk package(s) (e.g., 1 cargo tank), rather than an applicable unit of measurement (e.g., gallons, liters).

Q2. Must a shipping paper that describes a shipment of diesel fuel in a cargo tank motor vehicle include a "log" of the quantity dispensed from a cargo tank?

A2. There is no requirement under the HMR to include a "log" of the quantity dispensed on a shipping paper used for multiple deliveries. However, if a driver picks up additional quantities of hazmat, which were not previously indicated on the shipping paper, the additional quantities must be added if the total quantity on the vehicle exceeds that indicated on the shipping papers. PHMSA understands, however, that using one shipping paper for multiple deliveries is not common practice for transport by cargo tank motor vehicle. For more information, please see enclosed Letter of Interpretation, Ref. No. 03-0247.

Q3. Does the shipping paper that your company provided comply with the shipping paper requirements found in Part 172, Subpart C—Shipping Papers?

A3. It is the opinion of this Office that the shipping paper provided satisfies the shipping paper requirements of the HMR. However, you may wish to consider making the emergency response telephone number information more "prominent," such as by highlighting, using a larger font or a font that is a different color from other text, or otherwise setting the information apart to provide for quick and easy recognition, as described in § 172.604. In addition, you may wish to modify the "Total Quantity" section of the shipping paper to read "___ Cargo Tank(s)" instead of "___ Tank(s)" since this is more descriptive of your scenario and the exception referred to in § 172.202(a)(5)(iii)(A) specifically uses this language.

I hope this answers your inquiry. If you need additional assistance, please contact this Office again.



Dirk Der Kinderen
Acting Chief, Standards Development Branch
Standards and Rulemaking Division


172.202(a)(5)(iii)(A), 172.604

Regulation Sections

Section Subject
172.202 Description of hazardous material on shipping papers
172.604 Emergency response telephone number