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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 #23-0056

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

Interpretation Response Details

Response Publish Date:

Company Name: Hazmat Resources, Inc.

Individual Name: Mr. Daniel Shelton

Location State: TN Country: US

View the Interpretation Document

Response text:

November 28, 2023

Mr. Daniel Shelton
President
Hazmat Resources, Inc.
141 Wendover Dr.
Kingsport, TN  27660

Reference No. 23-0056

Dear Mr. Shelton:

This letter is in response to your June 20, 2023, email and subsequent phone call with a member of my staff 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 reference the letter "G" in Column 1 of the § 172.101 Hazardous Materials Table (HMT). The letter "G" in Column 1 of the HMT identifies proper shipping names for which one or more technical names of the hazardous material must be entered in parenthesis, in association with the basic description. In the subsequent phone call you requested clarification as to when the inclusion of a technical or chemical name would be acceptable for a hazardous material listed in the HMT that does not have the letter "G" in Column 1. As an example, you note that the entry "UN1987 Alcohol, n.o.s., Class 3, PG III" does not have the letter "G" in Column 1 in the HMT, and ask whether the following description is in compliance with the HMR: UN1987 Alcohol n.o.s., (Denatured Alcohol and Ethanol), Class 3, PGIII (1 Tank).

The HMT has several entries that do not include the letter "G" in Column 1 of the HMT, such as "UN1987 Alcohol n.o.s." However, as provided in § 172.202(d), technical and chemical group names may be entered in parenthesis between the proper shipping name and hazard class or following the basic description. It is the opinion of this Office that the addition of the text, "(Denatured Alcohol and Ethanol)" in association with the basic description as provided in your example is an acceptable description of the hazardous material on a shipping paper. Further, an appropriate modifier, such as "contains" or "containing," and/or the percentage of the technical constituent may also be used.

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, 172.202(d)

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table
172.202 Description of hazardous material on shipping papers