Interpretation Response #18-0062
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Crowell & Moring LLP
Individual Name: Jennifer A. Giblin
Location State: DC Country: US
View the Interpretation Document
Response text:
August 16, 2018
Jennifer A. Giblin
Senior Counsel
Crowell & Moring LLP
1001 Pennsylvania Avenue, NW
Washington, DC 20004
Reference No. 18-0062
Dear Ms. Giblin:
This letter is in response to your April 17, 2018, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to acceptable abbreviations for units of measure. You state that UNECE Recommendation No. 20 Annex I and Annex II provide "KGM" as the abbreviation for kilogram and ask if it is an acceptable abbreviation to indicate mass in kilograms on package markings or shipping papers under the HMR.
The answer is no. UNECE Recommendation No. 20 states under the "Principles for Inclusion in the Code List":
The codes are intended for application in everyday trade transactions where the increasing use of electronic data exchange makes it desirable to establish such codes. [T]he code list provides another international instrument for the harmonization of terms used in trade aiming at greater clarity and facility in the execution of international trade transactions.
In the HMR, abbreviations, when allowed, must be universally recognized to eliminate confusion between offerors, third-party logistics companies, carriers, enforcement agents, and other interested parties. The HMR is intended to communicate information regarding hazardous materials in transportation, not necessarily facilitate everyday trade transactions through electronic data interchange.
It is the opinion of this Office that the "common code" presented in Column 6 of UNECE Recommendation No. 20 Annex II is not an abbreviation or representational symbol for the unit of measure widely recognized by the hazardous materials community. Therefore, its use may create confusion and lead to frustration of hazardous materials shipments in transportation.
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