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Interpretation Response #22-0117


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

Interpretation Response Details

Response Publish Date: 07-24-2023
Individual Name: Mr. Nick Wright
Location state: KS    Country: US

View the Interpretation Document


Response text:

July 24, 2023

Mr. Nick Wright
1220 S. Enterprise
Olathe, KS  66061

Reference No. 22-0117

Dear Mr. Wright:

This letter is in response to your October 27, 2022, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the description of hazardous materials on shipping papers. In your email, you referenced a previous Letter of Interpretation (LOI) Ref. No. 15-0229R1 and note that it may relate to your specific question.

In LOI Ref. No. 15-0229R, we stated that "...PHMSA maintains that the term 'cargo tank' most appropriately describes the type of package; however, the term 'cargo tank motor vehicle' or 'CTMV' is acceptable..." and therefore the term "CTMV"—representing "one cargo tank motor vehicle"—is an acceptable description of total quantity, unit of measure, number, and type of package on a shipping paper as specified in § 172.202(a)(5) and (a)(7). As such, you ask whether the term "1 TRUCK LOAD" meets the requirements pertaining to a description of a hazardous material on a shipping paper as specified in § 172.202(a)(5)(iii)(A) and (a)(7) pertaining to the total quantity, unit of measure, number, and type of package.

Section 172.202(a)(5)(iii)(A) of the HMR provides that bulk packagings are excepted from the requirements specified in § 172.202(a)(5), provided some indication of the total quantity is shown on a shipping paper. Although "1 TRUCK LOAD" indicates a general description of the total quantity of the shipment, it is the opinion of this Office that it does not adequately describe the type of package containing the hazardous materials being transported and could result in the frustration of the shipment.

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)(5) and (a)(7), 172.202(a)(5)(iii)(A)


1 See 15-0229R (Nov. 3, 2016) at: https://www.phmsa.dot.gov/regulations/title49/interp/15-0229R


Regulation Sections

Section Subject
§ 172.202 Description of hazardous material on shipping papers