Interpretation Response #17-0092

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

Interpretation Response Details

Response Publish Date: 07/23/2018

Company Name: FedEx Custom Critical

Individual Name: Kellie Toth

Location State: OH Country: US

View the Interpretation Document

Response text:

May 01, 2018

Ms. Kellie Toth
Sr. Hazmat/Accident Specialist
FedEx Custom Critical
1475 Boettler Road
Uniontown, OH 44685

Reference No. 17-0092

Dear Ms. Toth:

This letter is in response to your August 23, 2017, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to shipping papers. You include a copy of a DataQ response letter from the Wisconsin Department of Transportation citing your company for incorrectly indicating the quantity and type of package on a shipping paper, as well as a copy of the shipping paper in question. You ask whether the shipping paper included with your letter conforms to the quantity and type of packaging provisions prescribed in § 172.202(a)(7).

The answer is yes. In accordance with § 172.202(a)(7), the shipping description of a hazardous material on a shipping paper must include the number and type of packages (e.g., "10 cylinders per box" and "5 fiberboard boxes") either before or after the required basic description. While it might not be in a format preferred by this Office, the shipping paper you provide does satisfy this requirement by placing a number (quantity) of packages directly under the applicable packaging in a heading of "BULK TOTE DRUM PAIL BOX." It is therefore the opinion of this Office that the shipping paper you include with your letter conforms to the requirements prescribed in § 172.202(a)(7).

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

Sincerely,

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

Regulation Sections