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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 #19-0056

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

Interpretation Response Details

Response Publish Date:

Company Name: Woodard & Curran

Individual Name: Kelly Camp

Location State: RI Country: US

View the Interpretation Document

Response text:

February 20, 2020

Kelly Camp, CHMM, CPEA
Regional Manager
Woodard & Curran
33 Broad Street
One Weybosset Hill, Floor 7
Providence, RI  02903

Reference No. 19-0056

Dear Ms. Camp:

This letter is in response to your May 7, 2019, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to shipping papers that describe "UN3291, Regulated medical waste, n.o.s., 6.2, Packing Group (PG) II." Specifically, you enclose a partially redacted sample shipping paper and ask for confirmation whether several entries on the shipping paper are acceptable under the HMR. We have paraphrased your questions and answered them in the order you provided.

Q1. The sample shipping paper includes Chemtrec's phone number as the emergency contact but the carrier, not the shipper, is contracted with Chemtrec to provide this emergency response service. You ask whether the shipper's use of Chemtrec as its emergency contact on its shipping paper is acceptable under the HMR.

A1. The answer is yes, provided the matter is agreed to and/or arranged for between the two parties, and the shipper ensures the emergency response information (ERI) provider has received current information on the shipper's material and agreed to provide this service for the shipper before the material or materials are offered for transportation.  See §§ 172.600 and 172.604. If these conditions have not been met, the answer is no.

Q2. The sample shipping paper includes the number and size of containers of regulated medical waste (RMW). You state that the "total" quantity of RMW may be calculated from this information, but does not appear on the shipping paper. You ask whether it is acceptable to leave the total quantity of RMW off the shipping paper.

A2. The answer is no. Section 172.202(a)(5) prescribes that the total quantity of hazardous material covered by a description must be indicated by mass or volume, or by activity for Class 7 materials, and must include an indication of the applicable unit of measurement.

As prescribed in § 172.202(c)(1), the number and type of packages must also be indicated on a shipping paper either before or after, or both before and after, the description required and authorized by the HMR.

Q3. Assuming the total quantity of the hazardous material on the sample shipping paper is placed near the number and type of containers, you ask whether the placement of the shipping description and total quantity on the sample shipping paper is acceptable.

A3. The answer is yes. There are no boundaries—written or otherwise—regarding what is considered an acceptable "after" location for the quantity of material covered by a description so long as it is not considered excessive. To that end, the location depicted in the sample shipping paper you provided is acceptable, provided there is a clear indication as to which quantity is the total quantity.

Q4. The shipper's certification language on the sample shipping paper does not match that found in § 172.204(a)(1) or (2). You ask whether the wording in this shipper's certification is acceptable under the HMR.

A4. The answer is no. As prescribed in § 172.204(a), each person who offers a hazardous material for transportation shall certify that the material is offered for transportation in accordance with the HMR by printing (manually or mechanically) on the shipping paper containing the required shipping description the certification prescribed in § 172.204(a)(1), or the certification (declaration) prescribed in § 172.204(a)(2). The certification in paragraph (a)(1) is intended for domestic purposes, and the certification in paragraph (a)(2) is intended for use in either domestic or international transportation (HM-215A; 59 FR 67390). For transportation by rail only, the certification may be received verbally or with an electronic signature in conformance with § 172.204(a)(3)(i) and (ii).

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

172.600, 172.604, 172.202(a)(5), 172.202(c)(1), 172.204(a)(1), 172.204(a), 172.204(a)(2), 172.204(a)(3)(i) and (ii)

Regulation Sections

Section Subject
172.202 Description of hazardous material on shipping papers
172.204 Shipper's certification
172.600 Applicability and general requirements
172.604 Emergency response telephone number