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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 #15-0222 ([COWAN] [Mr. J. David Shaeffer])

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

Interpretation Response Details

Response Publish Date:

Company Name: COWAN

Individual Name: Mr. J. David Shaeffer

Location State: MD Country: US

View the Interpretation Document

Response text:

January 07, 2016

Mr. J. David Shaeffer
1910 Halethorps Farms Rd.
Baltimore, MD 21227

Ref. No. 15-0222

Dear Mr. Shaeffer:

This is a response to your October 30, 2015 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) regarding shipping paper requirements.  It is your understanding only the initial U.S. carrier is required to maintain a shipping paper with the shipper’s certification.

With respect to highway transport of hazardous material, your understanding is correct.  In accordance with § 177.817(b), the shipper is required to provide the initial highway carrier with a shipping paper that includes a signed shipper’s certification.  Any subsequent highway carrier that transports the same hazardous material shipment is not required to be provided with or maintain the shipper’s certification; however, secondary carriers must maintain a shipping paper that otherwise conforms to Part 172, Subpart C.

Your further questions are paraphrased and answered as followed:  

Q1.  What information is required on shipping papers accompanying a highway carrier shipment transferred from a rail or water carrier?

A1.  Shipping papers for hazardous material transportation must be prepared in accordance with 49 CFR Part 172, Subpart C, and contain all information relevant to the hazardous material being shipped (See, for example, § 172.202).  

Q2.  Is the proper shipping name and emergency response number required on shipping papers?  

A2.  Yes (see A1).  Unless excepted by the HMR, proper shipping name(s) and an emergency response number are required on shipping papers.  The proper shipping name as prescribed for the materiel as shown in Column (2) of the § 172.101 table is just one of many informational requirements for description of hazardous material under § 172.202.

Furthermore, except under certain conditions, a shipping paper must contain an emergency
response telephone number, and if utilizing an emergency response information telephone number service provider, must identify the person (by name or contract number) who has a contractual agreement with the service provider in accordance with § 172.201(d).

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


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

177.817(b), 172.202, 172.101, 172.201(d)

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table
172.201 Preparation and retention of shipping papers
172.202 Description of hazardous material on shipping papers
177.817 Shipping papers