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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 #18-0097

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

Interpretation Response Details

Response Publish Date:

Company Name: CFI Drive

Individual Name: Jeff Messer

Location State: MO Country: US

View the Interpretation Document

Response text:

October 4, 2018

Jeff Messer
Safety Analyst
CFI Drive
4701 East 32nd Street
Joplin, MO  64804

Reference No. 18-0097

Dear Mr. Messer:

This letter is in response to your June 29, 2018, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to shipping paper requirements.  Specifically, you submitted a copy of a hazardous material shipping paper and asked if the numbering on the pages of the shipping paper met the requirements in § 172.201(c). 

The answer is no.  A hazardous material shipping paper may consist of more than one page if each page is consecutively numbered and the first page bears a notation specifying the total number of pages included in the shipping paper.  The hazardous material shipping paper you submitted consists of four pages, while the only indication of the total number of pages on the first page titled “Bill of Lading,” states “Page 1 of 1” and the four pages are not consecutively numbered.

Additionally, please note that the shipper’s certification is incorrect.  For clarity and consistency, the certification must be reproduced word-for-word from one of the applicable options in § 172.204.  Abbreviations—for instance, “DOT” in place of “Department of Transportation”—are not acceptable.

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

172.201(c), 172.204

Regulation Sections

Section Subject
172.201 Preparation and retention of shipping papers
172.204 Shipper's certification