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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 #18-0004

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

Interpretation Response Details

Response Publish Date:

Company Name: Commercial Vehicle Safety Alliance

Individual Name:

Location State: MD Country: US

View the Interpretation Document

Response text:

July 13, 2018

Collin Mooney
Executive Director
Commercial Vehicle Safety Alliance
6303 Ivy Lane, Suite 310
Greenbelt, MD 20770

Reference No. 18-0004

Dear Mr. Mooney:

This letter is in response to your January 5, 2018, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to documenting the criticality safety index (CSI) on shipping papers in accordance with § 172.203(d)(6)(ii). You state that shipping paper requirements for consignments containing fissile materials are unclear because of recent changes to the definition of CSI in § 173.403 and that it is your understanding that this definition does not apply to any part of the HMR other than Subpart I of Part 173. Specifically, you ask whether it is acceptable to show only the arithmetic sum of the CSIs for all the Class 7 fissile material packages in an overpack, freight container, consignment, or conveyance on a shipping paper in lieu of providing the CSI for each individual package.

The answer is no. To comply with the additional description requirements in § 172.203(d)(6)(ii), the CSI for each individual package of fissile material must be indicated on the shipping paper, rather than the arithmetic sum of packages in an overpack, freight container, consignment, or conveyance. The CSI for the individual packages in your consignment should be determined in accordance with 10 CFR 71.22, 71.23, and 71.59, as outlined in § 173.403. For purposes of requirements for the preparation of shipping papers, § 172.201(a)(4) allows additional information concerning a material on a shipping paper if the information is not inconsistent with the required description and is placed after the basic description.

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

Sincerely,

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

172.203(d)(6)(ii), 173.403, 172.201(a)(4)

Regulation Sections

Section Subject
172.201 Preparation and retention of shipping papers
172.203 Additional description requirements
173 SHIPPERS-GENERAL REQUIREMENTS FOR SHIPMENTS AND PACKAGINGS
173.403 Definitions