Interpretation Response #25-0074
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Campbell’s Express
Individual Name: Sam Klein
Location State: NJ Country: US
View the Interpretation Document
Response text:
September 12, 2025
Sam Klein
Chief Information Officer
Campbell's Express
P.O. Box 119
Pitman, NJ 08071
Reference No. 25-0074
Dear Mr. Klein:
This letter is in response to your May 28, 2025 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the proper display of hazardous material information on a shipping paper. Specifically, you are seeking confirmation of your understanding of how information should be provided on a bill of lading (i.e., shipping paper) containing hazardous material information for “UN3091, Lithium metal batteries contained in equipment including lithium alloy batteries, 9" and “UN3481, Lithium ion batteries contained in equipment including lithium ion polymer batteries, 9." You provide a copy of a hazardous materials shipping paper that lists both materials “UN3091” and “UN3481” and ask several questions regarding this document.
We have paraphrased and answered your questions as follows:
Q1. A customer is packing "UN3481" and "UN3091" together in the same packaging. The shipping paper, as shown in your incoming letter, represents both UN identification numbers (UN ID) on the same line. Should the UN ID (as well as the proper shipping name (PSN)) of each hazardous material be displayed on separate lines on the shipping paper?
A1. Yes. The hazardous material shipping description on a shipping paper must show associated information, such as the UN ID and PSN, for each hazardous material on separate lines (e.g., separate table entries). Although this is not explicitly stated in Part 172, Subpart C, each hazardous material has its own entry on a shipping paper to avoid confusion about the information presented for emergency response and enforcement personnel.
Q2. The shipping paper, as shown in your incoming email, lists the total combined weight of both hazardous materials in the single description. Should the weight for each UN ID (i.e., each hazardous material) be listed separately on the shipping paper?
A2. Yes. Section 172.202, at paragraphs (a)(5) and (6), instructs a person to include the total quantity of each hazardous material listed on the shipping paper.
Q3. The shipping paper, as shown in your incoming email, includes a column captioned "HM" to identify a hazardous material but no "X" is included next to the hazardous materials description. Should there be an "X" in the "HM" column for the hazardous material?
A3. No. Section 172.201(a) provides instruction on how to represent a hazardous material on a shipping paper when both hazardous materials and non-hazardous materials are described on the same shipping paper. The options are to enter the hazardous material first, enter the hazardous material information in a contrasting color (or highlighted), or identify the hazardous material entry with an "X" placed in a column captioned "HM." In the scenario presented in your incoming email, the hazardous material is listed first on the shipping paper, so there is no need to place an "X" in a column captioned "HM."
Q4. The shipping paper, as shown in your incoming email, does not specify the package type for the hazardous materials either before or after the hazardous materials description. Instead, the shipping paper contains a column captioned "CartonCnt" indicating the number of packages. Is this sufficient for indicating the number and type of packages as required in § 172.202(a)(7)?
A4. No. The column captioned "CartonCnt" is not sufficient for indicating the type of packages for each hazardous material shipping description. In accordance with § 172.202(a)(7), the number and type of packages must be indicated in the shipping description for the hazardous material. The type of packages must be indicated by description of the package (for example, “12 drums”). Further, the type of packaging may be entered in any appropriate manner before or after the basic description and abbreviations may be used to express types of packagings.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
Dirk DerKinderen
Chief, Standards Development Branch
Standards and Rulemaking Division
§ 172.201(a), § 172.202, § 172.202(a)(7),