Interpretation Response #24-0045
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Oak Harbor Freight Lines
Individual Name: Joe Guzman
Location State: CA Country: US
View the Interpretation Document
Response text:
Joe Guzman
Central/Southern Districts Safety Supervisor
832 F St West
Sacramento, CA 95605
Reference No. 24-0045
Dear Mr. Guzman:
This letter is in response to your June 7, 2024, email and subsequent phone calls with a member of my staff requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the hazardous materials description on shipping papers. You ask about a paint kit that is comprised of two different hazardous materials that are individually packaged and then placed in a single drum, which functions as the outer packaging of a combination packaging. Specifically, you ask whether the requirement to indicate the number and type of packages as part of the shipping description—as specified in § 172.202(a)(7)—is fulfilled by indicating that the shipment contains one package (i.e., drum) for the entire consignment (i.e., paint kit) as shown below:
|
# Packages |
HM |
Quantity |
Pack Description |
Classification Description |
Weight |
|---|---|---|---|---|---|
|
1 |
X |
3.79 L
15.14L |
ALL ONE DRUM |
UN2735, AMINES, LIQUID, CORROSIVE, N.O.S. (FATTY ACIDES, TALL OIL, REACTION PRODUCTS WITH TETRAETHYLPENTAMINE, TETRAETYHLYPENTAMINE),8, PGIII UN1263, PAINT, 3, PGIII |
9 LBS
91 LBS |
The answer is yes. It is the opinion of this Office that for a combination package, it is appropriate to list the outer packaging as the package type on the shipping paper. Additionally, where multiple hazardous materials described by differing Hazardous Materials Table entries are contained in a combination packaging, they should be entered on sequential rows so that the total quantity associated with each description is clearly identified.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division
172.202(a)(7)
Regulation Sections
| Section | Subject |
|---|---|
| 172.202 | Description of hazardous material on shipping papers |