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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 #19-0081

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

Interpretation Response Details

Response Publish Date:

Company Name: North American Transportation Consultants

Individual Name: William Herman

Location State: NJ Country: US

View the Interpretation Document

Response text:

October 8, 2019

William Herman
North American Transportation Consultants
P.O. Box 1440
Hightstown, NJ  08520

Reference No. 19-0081

Dear Mr. Herman:

This letter is in response to your June 12, 2019, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to a shipper's certification on a shipping paper.

In the scenario you describe, a shipment was made in a cargo tank supplied by the carrier and, in accordance with § 172.204(b)(1)(i), a shipper's certification was not required. However, a certification statement was provided on the shipping paper and contained a misspelling; specifically, "accurately" was spelled "accuratly" in the certification statement.

We have paraphrased and answered your questions as follows:

Q1. You ask whether a shipper's certification that appears on a shipping paper when the certification is not required must otherwise conform to § 172.204.

A1. The answer is no. If a shipper's certification is not required due to an exception provided by § 172.204(b), the requirements for the certification statement in § 172.204(a) do not apply.

Q2. You ask, if the answer to question Q1 is yes, whether the misspelling of the word "accurately" constitutes a bona fide modification to the language prescribed in § 172.204(a)(2).

A2. See A1.

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

172.204, 172.204(a), 172.204(a)(2), 172.204(b)(1)(i)

Regulation Sections

Section Subject
172.204 Shipper's certification