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Interpretation Response #21-0024

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

Interpretation Response Details

Response Publish Date:

Company Name: Matson Navigation Company

Individual Name: James Owen

Location State: AZ Country: US

View the Interpretation Document

Response text:

May 10, 2021

James Owen
Dangerous Goods Specialist
Safety, Quality, Environment, and Security
Matson Navigation Company
426 N 44th St, Ste 250
Phoenix, AZ  85008

Reference No. 21-0024

Dear Mr. Owen:

This letter is in response to your March 9, 2021, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the use of italicized text and plural versus singular shipping names on shipping papers. Specifically, you ask:

Q1. Section 172.101(c)(2) states that words in italics are not part of the proper shipping name, but may be used in addition to the proper shipping name. You ask whether someone may use only a portion of the italicized text.

A1. In general, the answer is yes. However, use of only part of the italicized text is not advised as it may misrepresent the hazard and cause frustration of your shipment. For example, the Hazardous Materials Table (HMT; § 172.101) entry "UN2037, Receptacles, small, containing gas or gas cartridges (oxidizing), without release device, not refillable and not exceeding 1 L capacity" may not be represented on a shipping paper as "UN2037, Receptacles, small, containing gas (oxidizing), without release device, not refillable and exceeding 1 L capacity."

Q2. You ask whether it is acceptable to enter a shipping description as singular when the HMT entry is plural. In your email, you provide the example of "fire extinguishers" entered as "fire extinguisher."

A2. The answer is yes. Section 172.101(c)(1) states that proper shipping names may be used in the singular or the plural and in either upper or lower case letters. Therefore, a shipper may enter the proper shipping names on a shipping paper in the singular or plural form. For example: “UN1044, Fire extinguishers” or "UN1044, Fire extinguisher" is acceptable.

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

172.101, 172.101(c)(1), 172.101(c)(2)

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table