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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 #20-0017

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

Interpretation Response Details

Response Publish Date:

Company Name: New York State Police

Individual Name: Robert A. Kidder

Location State: NY Country: US

View the Interpretation Document

Response text:

May 22, 2020

Robert A. Kidder
Technical Sergeant
New York State Police
State Route 7, Box 300
Sidney, NY 13838

Reference No. 20-0017

Dear Sergeant Kidder:

This letter is in response to your February 20, 2020, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the requirements for hazardous materials (hazmat) shipping papers.  Specifically, you ask whether certain abbreviations indicated on Environmental Protection Agency (EPA) Form 8700-22 would comply with the requirements of the HMR to include the type of packaging and unit of measurement on the hazmat shipping paper.

We have paraphrased and answered your questions as follows:

Q1. You ask whether "DF" as indicated on EPA Form 8700-22 is an acceptable abbreviation for a "plastic drum" when describing the packaging type on a hazmat shipping paper.

A1. Section 172.202(a)(7) of the HMR requires that the number and type of packages be entered as part of the shipping description on a hazmat shipping paper. This section allows for the use of abbreviations to indicate the type of packaging provided the abbreviations are commonly accepted and recognizable. Although the abbreviation "DF" is commonly used on EPA hazardous waste manifests to indicate the presence of plastic and/or fiberboard drums, it may not be easily recognizable without the use of a legend or list of abbreviations. Therefore, to avoid confusion in the enforcement or emergency response community that may result in the issuance of a ticket or frustration of the shipment, it is recommended that a legend of EPA's abbreviations be included on the hazmat shipping paper.

Q2. You ask whether "P" as indicated on EPA Form 8700-22 is an acceptable abbreviation for "pounds" when describing the total quantity of liquid hazardous material on a hazmat shipping paper.

A2. Section 172.202(a)(5) of the HMR requires that the total quantity, including the unit of measurement of the hazardous materials covered by the description, be included on a hazmat shipping paper (except for bulk packages, cylinders, and packages containing only hazardous material residue). Abbreviations may also be used to express units of measurement. Similar to Answer A1, although the abbreviation "P" is commonly used on EPA hazardous waste manifests to indicate total weight in pounds, it may not be easily recognizable without the use of a legend or list of abbreviations. Therefore, to avoid confusion in the enforcement or emergency response community that may result in the issuance of a ticket or frustration of the shipment, it is recommended that a legend of EPA's abbreviations be included on the hazmat shipping paper.

I hope this information is helpful. Please contact us if we can be of further assistance.

Sincerely,

T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

172.202(a)(5), 172.202(a)(7)

Regulation Sections

Section Subject
172.202 Description of hazardous material on shipping papers