# RPS, Inc. — Hazardous Materials Safety Interpretation

- **operation:** document
- **citation:** 00-0001
- **title:** RPS, Inc. — Hazardous Materials Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 2000-03-07
- **effective on:** Not available
- **summary:** 00-0001 response to RPS, Inc. concerning 172.200.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-interpretation-00-0001.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-00-0001.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-00-0001
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2000/000001.pdf
**body:**

<<<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 2>>>

materials 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 3>>>

BAH
"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
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