Interpretation Response #26-0003
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Maryland Department of the Environment Hazardous Materials Transportation Section
Individual Name: Zachary Zaykoski
Location State: MD Country: US
View the Interpretation Document
Response text:
April 27, 2026
Mr. Zachary Zaykoski
Maryland Department of the Environment
Hazardous Materials Transportation Section
1800 Washington Boulevard Suite 105
Baltimore, MD 21230
Reference No. 26-0003
Dear Mr. Zaykoski:
This letter is in response to your January 7, 2026 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to shipping paper requirements. Specifically, you seek clarification on the intent of § 172.201(a)(1) regarding the identification of hazardous materials on a shipping paper that contains a significant amount of non-hazardous information.
We have paraphrased and answered your questions as follows:
Q1. Are the requirements in § 172.201(a)(1) to comply with having a hazardous material's basic description readily identifiable from any other non-hazardous descriptions on the shipping paper applicable to other than cargo related items?
A1. No. The requirements in § 172.201(a)(1) are only applicable to a mixed load of hazardous materials with non-hazardous materials and ensuring those items are properly and readily identifiable. In addition, § 172.201(a)(4) states that the shipping paper may contain additional information concerning the material, provided the information is not inconsistent with the shipping description and does not interfere with the basic description required by § 172.202(a).
Q2. Must the identification of hazardous materials in the scenario provided be accomplished by following one of the three methods prescribed in § 172.201(a)(1)?
A2. No. See answer A1.
Q3. Would the shipping paper provided in the incoming request constitute a violation
of the requirements in § 172.201(a)(1)?
A3. No. It is the opinion of this Office that the shipping paper provided in the incoming request for a letter of interpretation is not in violation of the requirements in § 172.201(a)(1).
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