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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 #15-0158 ([U.S. Water Services] [Ms. Lisa L. Neumann])

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

Interpretation Response Details

Response Publish Date:

Company Name: U.S. Water Services

Individual Name: Ms. Lisa L. Neumann

Location State: MN Country: US

View the Interpretation Document

Response text:

February 8, 2016

Ms. Lisa L. Neumann
Logistics Manager
U.S. Water Services
330 Cleveland St. S
Cambridge, MN 55008

Reference No. 15-0158

Dear Ms. Neumann:

This responds to your July 29, 2015 email in which you request clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) with regard to the provisions of § 172.202(a)(7). You include a copy of a letter from the Minnesota Department of Transportation citing your company for "incorrectly indicating the type of package on a shipping paper." You also attach copies of the inspection report forms that identify each violation.

In accordance with § 172.202(a)(7), the shipping description of a hazardous material on a shipping paper must include the number and type of packages (e.g., "10 cylinders per box" and "5 fiberboard boxes") either before or after the required basic description. In addition, § 172.202(a)(5) requires that, except for bulk packages, cylinders, and packages containing only hazardous material residue, the total quantity, including the unit of measurement of the hazardous materials covered by the description, be included in the shipping papers. Total quantity may be entered as net weight, gross weight, capacity, or as otherwise appropriate. Based on your description of the package (a 55 gallon plastic drum), it is the opinion of this Office that the descriptions, "503LB55 gal drum" and "541LB55 gal drum," would satisfy the requirements of § 172.202(a)(7). However, to avoid potential frustration of shipments, we advise that you include a space between the net quantity of hazardous material and the type of packaging (e.g., "503LB 55 gal drum") on your shipping paper.

I trust this satisfies your inquiry. Please feel free to contact us if you need further assistance.



Duane A. Pfund
International Standards Coordinator
Standards and Rulemaking Division


Regulation Sections

Section Subject
172.202 Description of hazardous material on shipping papers