Interpretation Response #24-0099

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

Interpretation Response Details

Response Publish Date: 10/21/2024

Company Name: Master Builders Solutions

Individual Name: Norm Stollberg

Location State: FL Country: US

View the Interpretation Document

Response text:

October 21, 2024

Norm Stollberg
Global Dangerous Goods Expert
Master Builders Solutions
7778 Four Seasons Blvd
Kissimmee, FL 34747

Reference No. 24-0099

Dear Mr. Stollberg:

This letter is in response to your September 11, 2024, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the description of hazardous materials on shipping papers. Specifically, you state that a freight forwarder refused to process your shipment because the words "US DOT" were on the shipping paper in association with the hazardous materials description. You state that the description on the shipping paper appeared as "US DOT: UN1760, Corrosive Liquid, N.O.S. (Nitrilotrimethylenetris (Phosphoric Acid)), 8, III, ERG 154, Danger Label: 8." Lastly, you seek confirmation that your understanding is correct that the basic description is in the correct sequence and is not interspersed with additional information.

Based on the information you have provided, it appears that your understanding is correct. As specified in § 172.202(b), the basic description specified in § 172.202(a)(1) through (4) must be shown in sequence with no additional information interspersed. It appears that the basic description you have provided is in the correct sequence and the additional information is outside of that description.

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

Sincerely,

Shane C. Kelley
Director
Standards and Rulemaking Division
Office of Hazardous Materials Safety

172.202(a)(1) through (4), 172.202(b)

Regulation Sections