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Interpretation Response #16-0182 ([Tom Dunaway and Associates, Inc.] [Mr. Tom Dunaway])

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

Interpretation Response Details

Response Publish Date:

Company Name: Tom Dunaway and Associates, Inc.

Individual Name: Mr. Tom Dunaway

Location State: AL Country: US

View the Interpretation Document

Response text:

January 04, 2017

Mr. Tom Dunaway
Tom Dunaway and Associates, Inc.
502 Big Creek Drive
Delta, AL  46258

Reference No. 16-0182

Dear Mr. Dunaway:

This letter is in response to your November 3, 2016, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the use of pre-printed shipping papers and recent changes to the Hazardous Materials Table (HMT).  Specifically, you reference a final rule published by the Pipeline and Hazardous Materials Safety Administration (PHMSA) on June 2, 2016, titled Hazardous Materials: Miscellaneous Amendments (RRR) [HM-218H; 81 FR 35483].  In this final rule, PHMSA revised certain HMT entries, including the removal of the packing group (PG) II designation for certain explosives.  As discussed in the preamble of this rulemaking, this amendment was intended to alleviate confusion and frustration of shipments, as well as align with international regulations.  

You indicate in your email that you currently ship explosives using pre-printed shipping papers that list the PG II designation in the basic description although it was removed in the HM-218H Final Rule.  Specifically, you ask if you may continue to use these pre-printed shipping papers.

The answer is yes.  In accordance with § 172.101(l)(1)(ii), when a change is made to the HMT, a shipper may continue to use pre-printed shipping papers until the supply is depleted or for a one-year period, subsequent to the effective date of a regulatory change to the HMT.  As the effective date of the HM-218H Final Rule was July 5, 2016, the pre-printed shipping papers may be used until they are depleted or through July 5, 2017, whichever comes first.  However, after July 5, 2017, a shipping paper may no longer display the PG II designation for those HMT entries changed in HM-218H.

Please note that absence of a PG designation in the HMT, and subsequently the shipping paper, does not affect United Nations (UN) packaging requirements.  In your scenario, packaging for an explosive must still meet PG II specification requirements, unless
otherwise noted, in accordance with § 173.60(a).  Furthermore, while no longer listed on the shipping paper, the PG standard to which the package was tested will be communicated on the UN package.

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


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

172.101(l)(1)(ii), 173.60(a)

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table
173.60 General packaging requirements for explosives