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Interpretation Response #99-0181 ([General Services Administration] [Mr. Bob Burnett])

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

Interpretation Response Details

Response Publish Date:

Company Name: General Services Administration

Individual Name: Mr. Bob Burnett

Location State: CA Country: US

View the Interpretation Document

Response text:

August 6, 1999


Mr. Bob Burnett                                 Ref.  No.  99-0181
General Services Administration
Bldg. 412-A
Rough & Ready Island
Stockton, CA 95203

Dear Mr. Burnett:

This is in response to your letter dated June 29, 1999, requesting clarification of a proper shipping description under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you asked if it was permissible for a coating kit containing two receptacles of coating solution, one classified as packing group (PG) II and the other classified as PG III, to be described under one shipping description as a PG II material.

The answer is no. A Class 3, PG III material may not be described on a shipping paper as a PG II material.  In the scenario you describe, the PG II and PG III coating solution should be described separately on your shipping paper.

I hope this satisfies your request.



John A. Gale
Transportation Regulations Specialists
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
172.202 Description of hazardous material on shipping papers