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Interpretation Response #98-0119 ([Department of California Highway Patrol] [Mr. R. B. Wood])

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

Interpretation Response Details

Response Publish Date:

Company Name: Department of California Highway Patrol

Individual Name: Mr. R. B. Wood

Location State: CA Country: US

View the Interpretation Document

Response text:

JUL 1, 1998


Mr. R. B. Wood                                     Ref. No.: 98-0119
Senior Traffic Officer
Department of California Highway Patrol
32951 Camino Capistrano
San Juan Capistrano, CA 92675

Dear Officer Wood:

This is in response to your letter requesting clarification of a quantity description on a shipping paper and the shipping description for gasoline.  I apologize for the delay in responding.

Your questions are paraphrased and answered as follows:

Question 1.  Would the term 2 steel bins be a proper total quantity description on a shipping paper for a transport vehicle carrying 2 IBC’s?

The answer is yes.  Any container with a maximum capacity greater than 450L (119 gallons) as a receptacle for a liquid, or a maximum net mass greater than 400 kg (882 lbs), and a maximum capacity greater than 450L (119 gallons) as a receptacle for a solid (see § 171.8, bulk packaging) is considered to be a bulk packaging.  Section 172.202 (a) (5) states that for bulk packages (e.g., IBCs), some indication of total quantity must be shown; the indication “2 steel bins” is acceptable. 

Question 2.  May a shipper of gasoline insert into the shipping description octane and temperature readings after the packing group and before the total quantity?

The answer is yes.  Section 172.201(a) (4) states that the shipping paper may contain additional information about the material provided the information is not inconsistent with the shipping description.  The additional information must appear after the basic description required by
§ 172.202 (a) (1), (2), (3), and (4).   

I trust this satisfies your inquiry.  If this office can be of further assistance, please contact us.



Delmer F. Billings
Chief, Standards  Development
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
172.202 Description of hazardous material on shipping papers