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Interpretation Response #21-0073

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

Interpretation Response Details

Response Publish Date: 09-02-2021
Company Name: Superior Plus Propane    Individual Name: Timothy Decker
Location state: NY    Country: US

View the Interpretation Document

Response text:

September 2, 2021

Mr. Timothy Decker
Field Health and Safety Specialist
Superior Plus Propane
1870 South Winton Road
Rochester, NY  14618

Reference No. 21-0073

Dear Mr. Decker:

This letter is in response to your July 8, 2021, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to shipping paper retention and recordkeeping requirements. You describe a scenario in which a shipping paper—describing "UN1075, Liquefied Petroleum Gas, 2.1"—is used for multiple shipments. In addition, you state that the carrier retains a record of each shipment made and describes the material as "1075 Propane LPG." You ask whether the description of the hazardous material on the shipping paper and the record of shipment must match exactly.

As you note in your email, the final sentence of paragraph (e) in § 172.201 states "A motor carrier (as defined in § 390.5 of subchapter B of chapter III of subtitle B) using a shipping paper without change for multiple shipments of one or more hazardous materials having the same shipping name and identification number may retain a single copy of the shipping paper, instead of a copy for each shipment made, if the carrier also retains a record of each shipment made, to include shipping name, identification number, quantity transported, and date of shipment." Therefore, it is the opinion of this Office that to comply with the above requirement, the proper shipping name and identification number on both the shipping paper and the record of each shipment must match.

In the scenario you describe, and the accompanying documents submitted with your request, the proper shipping names do not match.

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


Regulation Sections

Section Subject
§ 172.201 Preparation and retention of shipping papers