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Interpretation Response #15-0189 ([Kajuligan Corporation] [Mr. Clifford Croft])

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

Interpretation Response Details

Response Publish Date:

Company Name: Kajuligan Corporation

Individual Name: Mr. Clifford Croft

Location State: IL Country: US

View the Interpretation Document

Response text:

January 08, 2016

Mr. Clifford Croft
Kajuligan Corporation
1533 Kirkwood Drive
Geneva, IL 60134

Reference No. 15-0189

Dear Mr. Croft:

This responds to your September 21, 2015 email requesting clarification of the shipping paper requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether a multi-page shipping paper, consisting of a bill of lading and an attached shipping paper containing the hazardous material information, satisfies the shipping paper requirements. You state that you use an orange tab to identify the shipping paper containing the hazardous material information.

Under the HMR, a shipping paper means a shipping order, bill of lading, manifest or other shipping document serving a similar purpose and prepared in accordance with 49 CFR part 172 subpart C. See § 171.8. In accordance with § 172.201(c), a shipping paper may consist of more than one page, if each page is consecutively numbered and the first page bears a notation specifying the total number of pages included in the shipping paper. For example, "Page 1 of 4 pages." Section 172.201(a)(1) also prescribes that, if a hazardous material and non-hazardous material are listed on the same shipping paper (single- or multi-page), the hazardous material information must either be listed first, entered in a contrasting color, or "identified by the entry of an 'X' placed before the basic shipping description...in a column captioned 'HM'."

In addition, 49 CFR 177.817(e)(1) requires that the driver and carrier clearly distinguish a hazardous material shipping paper if it is carried with other shipping papers, bills of lading or documents of any kind. The shipping paper containing hazardous materials must be distinguished by either distinctly "tabbing" the shipping paper or having it appear first.

It is the opinion of this Office that the multi-page shipping paper you provided satisfies the shipping paper requirements of the HMR.

I hope this satisfies your inquiry. Please feel free to contact us if you have further questions.

Sincerely,

 

Duane A. Pfund
International Standards Coordinator
Standards and Rulemaking Division

171.8, 172.201(c), 172.201(a)(1), 177.817(e)(1)

Regulation Sections

Section Subject
171.8 Definitions and abbreviations
172.201 Preparation and retention of shipping papers
177.817 Shipping papers