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Interpretation Response #16-0157 ([Regulatory Resources Inc.] [Mr. W A Winters])

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

Interpretation Response Details

Response Publish Date:

Company Name: Regulatory Resources Inc.

Individual Name: Mr. W A Winters

Location State: NM Country: US

View the Interpretation Document

Response text:

January 12, 2017

Mr. W. A. Winters
Regulatory Resources Inc.
379 Aragon Avenue
Los Alamos, NM  87544

Reference No. 16-0157

Dear Mr. Winters:

This letter is in response to your September 23, 2016, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to shipping papers.  Specifically, you ask questions pertaining to the placement of certain entries as they relate to an example shipping paper you included in your letter.  We have paraphrased and answered your questions as follows:

Q1.   Section 172.202(c) requires the total quantity of hazardous material covered by one description to appear before or after, or both before and after, the description required and authorized by Subpart C of Part 172.  What other information, if any, is authorized to be placed before the required description?

A1.   As prescribed in §§ 172.201(a)(4) and 172.202(c), certain information may be placed before the basic description, such as quantity shipped, the type of packaging, and destination marks.  Otherwise, additional information must be entered on the shipping paper after the basic description prescribed in § 172.202(a).

Q2.   In the same scenario as Q1, how much “after” the required description can the total quantity of material be indicated for a shipping paper to be considered acceptable?  Does our example shipping paper meet that standard?   

A2.   There are no boundaries—written or otherwise—with regard to what is considered an acceptable “after” location for the quantity of material covered by a description so long as it is not considered excessive.  To that end, the location depicted in the example shipping paper you provided is acceptable.  

Q3. Does the type of package indicated in our example shipping paper meet the requirements of § 172.202(a)(7)?

A3.   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 example shipping paper provided with your letter does not meet that standard because the “RIDGED OR SHARPS US DOT TRANSPORT CONTAINER” field does not sufficiently describe a commonly recognizable package type.

Q4.   Does the emergency contact telephone number depicted in our example shipping paper meet the requirements of § 172.604(a)(3)(ii)?    

A4.   The answer is yes.  Section 172.604(a)(3)(ii) requires that the emergency contact telephone number be entered once on the shipping paper in a manner that sets the information apart to provide for quick and easy recognition.  The example location and method depicted in the shipping paper you provided meets this requirement.

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(c), 172.201(a)(4), 172.202(a), 172.202(a)(7), 172.604(a)(3)(ii),

Regulation Sections

Section Subject
172.201 Preparation and retention of shipping papers
172.202 Description of hazardous material on shipping papers
172.202 Description of hazardous material on shipping papers
172.202 Description of hazardous material on shipping papers
172.604 Emergency response telephone number