RPS, Inc. — Hazardous Materials Safety Interpretation

Page 1• S. Departmen Transportatio Washington, D.C 400 Seventh Street, S.W. 20590 MAR - 7 2000 Mr. Jerry W. Freeman Ref. No. Hazardous Materials Coordinator 00-0001 RPS, Inc. P.O. Box 108 Pittsburgh, PA 15230 Dear Mr. Freeman: This is in response to your letter dated December 21, 1999, and subsequent telephone conversation with a member of my staff regarding shipping paper requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your questions are paraphrased and answered as follows: Q1. May a carrier electronically generate a shipping paper at his facility for the purpose of consolidating multiple shipments offered by different shippers? A1. The answer is yes. Part 172, Subpart C does not specify a particular form in which a shipping paper must appear. However, regardless of the form, the shipping paper must contain all the applicable information as required under Part 172, Subpart C and meet the requirements in $ 177.817. 92. Must the carrier modify the shipping paper upon making intermediate hazardous material shipment drop-offs? A2. The answer is no. A driver is not required to update shipping paper to reflect a partial delivery. However, If a driver picks up additional quantities of hazardous 000001 172,200#

Page 2materials which were not previously indicated on the shipping paper, the additional quantities must be added if the total quantity on the vehicle at any time exceeds that indicated on the shipping papers. I hope this satisfies your request. Sincerely, / office of Hazardous Materials Standards Transportation Regulations Specialist#

Page 3BAH "We consider safety fust in our operation" $172.200 RINIS An FDX Company 00-000: P.O. Box 108 RPS, Inc., Safety Department (800) 762-3725 Pittsburgh, PA 15230 December 21, 1999 Information Center Office of Hazardous Material Standards Inited States Department of Transportation esearch & Special Programs Administratio 400 Seventh Street, S. W., Washington D.C. 20590-0001 I am writing to you on behalf of RPS, Inc. to get clarification on the Hazardous Material Regulations. My questions pertain to the definition of shipping papers and the use of the shipping paper on a package. 49CFR Part 171.8 defines shipping paper as a shipping order, bill of lading, manifest or other shipping document serving a similar purpose and containing the information required by §§ 172.202, 172.203 and 172.204. My two questions are: 1. Provided the appropriate emergency response information is present and available, can a computer-generated manifest serve as the shipping papers) as required by 49CFR 177.817 that contain multiple entries (shipments) from various shippers? 2. Provided the carrier satisfies all the requirements of highway transportation under 49CFR 177.817, can the shipping paper be in the form of a self-adhesive label without multi-parts and still meet the requirements of 49CFR 172.600? I appreciate your time and consideration in this matter. Should you have any questions, please do not hesitate to contact me at 412-262-7351. Respectfully, Jay. Treeman Jerry W. Freeman Hazardous Materials Coordinator cc: Elizabeth Bracci Winner of American "Trucking Associations' Presidents A ward for Safety#