Interpretation Response #26-0026
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: O.D.O.T. Commerce and Compliance Division
Individual Name: Mr. Andrew Zikmund
Location State: OR Country: US
View the Interpretation Document
Response text:
April 2, 2026
Mr. Andrew Zikmund
Compliance Specialist
O.D.O.T. Commerce and Compliance Division
5920 Highway
30 Huntington, OR 97907
Reference No. 26-0026
Dear Ms. Zikmund:
This letter is in response to your February 17, 2026 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the shipping paper and marking requirements of non-odorized liquefied petroleum gas (LPG).
We have paraphrased and answered your questions as follows:
Q1. Does the requirement in § 172.203(p) to enter the word “non-odorized” or "not-odorized" on a shipping paper apply to non-odorized shipments of "UN1011, Butane," "UN1978, Propane," and "UN1077, Propylene"?
A1. Yes. includes gases composed predominantly of the following either by themselves or as mixtures: butane, isobutane, propane, propylene (propene), and butylenes (butenes).1 Section 172.203(p) states that the word "non-odorized" or “not-odorized” must be included in association with the proper shipping description on a shipping paper when non-odorized LPG is offered for transportation. If the non-odorized gas or gas mixture meets the definition of LPG, then the shipping description must include "non-odorized" or "not-odorized" regardless of whether the assigned proper shipping name is specifically "Petroleum gas, liquefied or Liquefied petroleum gas."
1 49 FR 64462, 64463 (Nov. 4, 2004)
Q2. Does the marking requirement for "NON-ODORIZED" or "NOT ODORIZED" apply to these specific gases when offered in cylinders, portable tanks, or cargo tanks?
A2. Yes. The marking requirements in § 172.301(f) for cylinders, § 172.326(d) for portable tanks, and § 172.328(e) for cargo tanks apply to any non-odorized gas or gas mixture that meets the definition of LPG. Just as with the shipping paper requirements, if the LPG is offered for transportation without odorization, the package must be marked “NON-ODORIZED” or "NOT ODORIZED" as specified in the applicable section.
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
172.203(p); 172.301(f); 172.326(d); 172.328(e)