Interpretation Response #24-0020
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Public Utilities Commission of Ohio
Individual Name: Mr. Tom Bartfai
Location State: OH Country: US
View the Interpretation Document
Response text:
May 1, 2024
Mr. Tom Bartfai
Hazardous Materials Specialist, Motor Carrier & Rail Enforcement
Public Utilities Commission of Ohio
180 East Broad Street
Columbus, OH 43215
Reference No. 24-0020
Dear Mr. Bartfai:
This letter is in response to your March 20, 2024, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to shipping papers. In your email, you note that when a shipping paper contains both hazardous and non-hazardous materials, shippers must differentiate between the two using at least one of the methods indicated in § 172.201(a)(1).
We have paraphrased and answered your questions as follows:
Q1. Your incoming email and photo present a shipping paper which utilizes all three of the options listed in § 172.201(a)(1) simultaneously—i.e., the hazardous materials entries are entered first, the hazardous materials entries are identified by the entry of an "X" placed before the basic shipping description in a column captioned "HM", and the hazardous materials basic shipping descriptions are highlighted. You ask whether—as shown in the photo—it is permissible to highlight more than just the basic shipping description.
A1. The answer is yes, provided the additional highlighted information on the shipping paper is associated with—and is consistent with—the hazardous materials being shipped.
Q2. If the highlight option in § 172.201(a)(1)(ii) is the only method used to differentiate between hazardous materials and non-hazardous materials on a shipping paper, you ask whether it is acceptable to highlight more than the basic description as seen in the photo you provided.
A2. Please see answer A1.
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
172.201(a)(1), 172.201(a)(1)(ii)
Regulation Sections
| Section | Subject |
|---|---|
| 172.201 | Preparation and retention of shipping papers |