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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 #17-0126

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

Interpretation Response Details

Response Publish Date:

Company Name: FedEx

Individual Name: Melissa Owens

Location State: OH Country: US

View the Interpretation Document

Response text:

Melissa Owens
HazMat/Accident Specialist
1475 Boettler Road
Uniontown, OH 4685

Reference No. 17-0126

Dear Ms. Owens:

This letter is in response to your November 15, 2017, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to shipping papers. Specifically, you ask whether a shipping paper must list the quantity and type of packaging for each hazardous material that is placed inside of an overpack. You further ask if the sample shipping paper included with your letter meets the requirements of § 172.202(a)(7) and (c)(1).

The number and type of packages must be indicated on a shipping paper either before or after the required basic description as outlined in § 172.202(a)(7) and (c)(1). The type of packages must be indicated as a description of the package (i.e., "12 drums"). Placing packages containing hazardous materials in an overpack would not negate the need to identify the quantity of the hazardous material on a shipping paper. Therefore, the sample shipping paper included with your letter does not meet the HMR requirements.

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

Regulation Sections

Section Subject
172.202 Description of hazardous material on shipping papers