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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 #18-0085

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

Interpretation Response Details

Response Publish Date:

Company Name: Corp Safe Logistics

Individual Name: Carolyn Geile

Location State: MO Country: US

View the Interpretation Document

Response text:

October 11, 2018

Carolyn Geile
Corp EHS, Manager Safe Logistics
Corp Safe Logistics
2838 Olive Street
Saint Louis, MO  63103

Reference No. 18-0085

Dear Ms. Geile:

This letter is in response to your May 31, 2018, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to overpacks shipped internationally by air.  Specifically, you ask if the total quantity per overpack must be provided on the shipping paper when the overpack consists of only one UN identification number in accordance with international standards. 

The HMR do not require that the total quantity per overpack be indicated on the shipping paper.  While § 172.202(a)(7) of the HMR requires that the number and type of packages be indicated on the shipping paper, this section only addresses individual packages and does not apply to overpacks.  However, a shipper may include information regarding the use of an overpack on the shipping paper as additional information. 

Similarly, the International Civil Aviation Organization’s (ICAO) Technical Instructions for the Safe Transport of Dangerous Goods by Air require that the use of an overpack be indicated on the shipping paper, but do not specifically require a total quantity per overpack; see ICAO Technical Instructions Part 5; Chapter 4, Section 1.5.8.  Note that while the HMR do not officially recognize the International Air Transport Association (IATA) Dangerous Good Regulations for purposes of transporting hazardous materials, IATA may be more prescriptive than ICAO in regard to these requirements.  We encourage you to contact IATA for further clarification at:

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


Regulation Sections

Section Subject
172.202 Description of hazardous material on shipping papers