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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 #23-0075

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

Interpretation Response Details

Response Publish Date:

Company Name:

Individual Name: Roy Kluthe

Location State: OR Country: US

View the Interpretation Document

Response text:

April 4, 2024

Mr. Roy Kluthe
8712 North Decatur St.
No. 503
Portland, OR  97203

Reference No. 23-0075

Dear Mr. Kluthe:

This letter is in response to your July 5, 2022 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to shipping papers. Specifically, you ask whether a shipping paper containing columns may include a company slogan or other non-regulatory information directly below the shipping description. You provided an example of a shipping paper, and below is a redacted excerpt with the text you are concerned about:

Units HM Description of Materials, Special Marks and Exceptions Weight
1 T/T

X

Delivery No: 12345678    Order: 1234567

UN 1830 SULFURIC ACID, 8, II
RQ (Sulfuric acid)

ERG GUIDE No. 137
O/Y Order ref: 86588/
SULFURIC ACID 93% TECHNICAL BULK
Excellence in Performance # Pride in Achievement

50000 LB

In general, company slogans and additional information that are not part of the shipping description must be placed after the information required under § 172.202(a). In the example you provided, the text "Excellence in Performance # Pride in Achievement" is clearly not part of the basic description and also not interspersed in the description. Provided the additional non-regulatory information is not inconsistent with the required shipping description, it is the opinion of this Office that—in the specific example you provided in your letter—the additional non-regulatory information would not be a violation of the HMR.

I hope this information is helpful. Please contact us if we can be of further assistance.

Sincerely,

Steven Andrews
Acting Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

172.202(a)

Regulation Sections

Section Subject
172.202 Description of hazardous material on shipping papers