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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 #16-0148 ([XPO Logistics Freight (XPOLTL)] [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:

Company Name: XPO Logistics Freight (XPOLTL)

Individual Name: Ms. Marie Easley Cook

Location State: MI Country: US

View the Interpretation Document

Response text:

January 12, 2017

Ms. Marie Easley Cook
Hazardous Materials Administrator, Sr
XPO Logistics Freight (XPO LTL)
2211 Old Earhart Road
Suite 100
Ann Arbor, MI  48105

Reference No. 16-0148

Dear Ms. Cook:

This letter is in response to your August 31, 2016, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to shipping papers.  Specifically, you ask whether the number and type of package entry required by
§ 172.202(a)(7) may be split in two, that is, where the number is placed before the basic description and the type of package is placed after the basic description.

The answer is no.  The number and type of packages must be indicated on a shipping paper either before or after the required basic description.  See §§ 172.202(a)(7) and 172.202(c).  The type of packages must be indicated as a description of the package (i.e., “12 drums”).

The requirement to indicate the number and type of packages together on a shipping paper enhances the safety and security of hazardous materials transportation.  When incidents occur during transportation, it is essential for emergency responders at the scene to easily ascertain the number of packages present in a given shipment when determining emergency response actions.

Furthermore, the requirement to indicate the number and type of packages facilitates accountability.  It promotes public safety and allows carriers, transportation workers, emergency responders, and law enforcement personnel to quickly determine whether packages may be missing, such as from theft.  The requirement also assists law enforcement personnel in identifying questionable shipments where further investigation may be warranted.  

I hope this information is helpful.  Please contact us if we can be of further assistance.


T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

172.202(a)(7), 172.202(c)


Regulation Sections

Section Subject
172.202 Description of hazardous material on shipping papers
172.202 Description of hazardous material on shipping papers