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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 #23-0050

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

Interpretation Response Details

Response Publish Date:

Company Name: SBS Transportation, Inc

Individual Name: Billy Murphy, Jr.

Location State: MN Country: US

View the Interpretation Document

Response text:

June 3, 2024

Billy Murphy, Jr.
Safety & Compliance Manager
SBS Transportation, Inc.
1700 Wynne Ave.
St. Paul, MN  55108

Reference No. 23-0050

Dear Mr. Murphy:

This letter is in response to your May 12, 2023, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to shipping papers. In your email, you provide an example of a hazardous material description included in a shipping paper and ask whether other columns or information may be placed between the "HM" column and the basic description in accordance with § 172.201(a)(1)(iii).

The answer is no. The hazardous material entry must be clearly and readily identifiable when described on the same shipping paper with materials not subject to the HMR. The basic description consisting of the proper shipping name, hazard class, identification number, and packing group, must be shown in proper sequence, as required in § 172.202(a) and (b). As stated in § 172.201(a)(1)(iii), the "X" must be placed in the HM column before the basic shipping description so as to clearly identify it as a hazardous material. Any additional information required by § 172.202, specifically, the total quantity of the hazardous material, number and type of packages. and destination marks may be placed before or after the basic description.

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

172.201(a)(1)(iii), 172.202, 172.202(a) and (b)

Regulation Sections

Section Subject
172.201 Preparation and retention of shipping papers
172.202 Description of hazardous material on shipping papers