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Interpretation Response #25-0103

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

Interpretation Response Details

Response Publish Date:

Company Name: Lennox Corporate

Individual Name: Robert (Bob) Johnson

Location State: TX Country: US

View the Interpretation Document

Response text:

September 30, 2025

Mr. Robert (Bob) Johnson
Lennox Corporate
2140 Lake Park Blvd.
Richardson, TX  75080

Reference No. 25-0103

Dear Mr. Johnson:

This letter is in response to your July 23, 2025 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the preparation of shipping papers. You provide a sample shipping paper and note that you were previously issued guidance that the sample provided meets the requirements in § 172.201(a)(1)(i). Furthermore, you note that a carrier recently expressed concern with use of the term "Dangerous Goods" as a header for each hazardous material description as shown in the sample shipping paper. You ask whether the sample provided complies with the shipping paper requirements in § 172.201(a).

Yes. Display of the term "Dangerous Goods" in the manner shown does not conflict the requirements for the description of hazardous materials on a shipping paper. Moreover, when describing hazardous materials that are included on a shipping paper, a person is required to use one of the methods listed in § 172.201(a)(1)(i) through (a)(1)(iii), as the word "or" (emphasis added) is used to indicate three separate options to identify hazardous materials on a shipping paper. Listing the hazardous materials first as shown in the sample shipping paper provided in your incoming letter meets the requirements in § 172.201(a)(1)(i).

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), § 172.201(a)(1)(i), § 172.201(a)(1)(ii), § 172.201(a)(1)(iii)

Regulation Sections

Section Subject
172.201 Preparation and retention of shipping papers