Interpretation Response #19-0103
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: J Lazarus Consulting & Training, LLC
Individual Name: Josh Lazarus
Location State: FL Country: US
View the Interpretation Document
Response text:
January 31, 2020
Josh Lazarus
J Lazarus Consulting & Training, LLC
11663 Spotted Margay Avenue
Venice, FL 34292
Reference No. 19-0103
Dear Mr. Lazarus:
This letter is in response to your July 25, 2019, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to shipping papers. You describe a scenario in which pyrotechnic articles and flammable gases are transported by highway to multiple venues in support of an entertainment enterprise. You state that the operator begins the tour with a supply of hazardous materials and draws down on the stock as the tour progresses. You further add that the unused items from each show are resealed and reloaded on the truck for use at the next show. You ask whether a new shipping paper is required in this scenario when moving from one destination to another.
The answer to your question is yes. Unless otherwise excepted, a shipping paper is required each time a shipment of hazardous materials is offered for transportation. In your scenario, this accounts for each venue where hazardous materials are unloaded and subsequently repackaged. However, § 172.201(e) permits use of a single (permanent) shipping paper without change for multiple shipments of one or more hazardous materials having the same shipping name and identification number. When using a permanent shipping paper for multiple shipments, there must be a record of each stop that reflects the shipping name, identification number, quantity transported, and date of shipment after repackaging/reloading the hazardous materials.
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
172.201(e)
Regulation Sections
| Section | Subject |
|---|---|
| 172.201 | Preparation and retention of shipping papers |