Overnite Transportation Company — Hazardous Materials Safety Interpretation

Page 18. of Transportation U.S. Department 400 Seventh St., S.W. Research and Washington, D.C. 20590 Special Programs Administration AUG 3 2000 Mr. Garry Howell Overnite Transportation Company Ref. No. 00-0185 PO Box 246 Gaffney, SC 29342 Dear Mr. Howell: This is in response to your letter dated June 29, 2000, regarding units of measurement required in a shipping paper entry under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if the quantity of a material listed on a shipping paper must include units of measurement, or if the units of measurement may appear at the top of a column as a heading. Section 172.202(a)(5) requires that the total quantity, including the unit of measurement, of the hazardous material covered by the description to appear on the shipping paper. Displaying the unit of measurement at the top of a column as a heading, rather than by each entry, is an acceptable method for compliance. However, the unit of measurement listed at the top of a column must apply to every entry below it and must appear on every page of multi-page shipping papers. I hope this information is helpful. If you have further questions, please do not hesitate to contact this Office. Sincerely, dha 75.19 Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 172,202 000185#

Page 2JUN 29 2008 15:33 FR OUERNITE TRANSPOTATIN864 487•5694 TO 12023663012 P.Ø5/05 OVERNITE TRANSPORTATION COMPANY COVERNITE, P.O. BOX 246 / GAFFNEY, SC 29342 nelson 6/29/2000 172.202 Director Of Hazardous Materials Standards Mr. Edward Mazullo 00 - 0185 washington, DC 20590 400 seventh street, 5.w. Dear MI. Mazullo: in regards to a violation Shipping papers. The inspector references Violation Code Violation concerns the unit of measure being shown on the • олено оба 188.817(a) which will then refer you to 172.202(a)5,8 (c). column headed by the word: [WEIGHT (Ibs)] is an appropriate It is our understanding that a shipping document with a shipping document #1 but this shipping document was not setup for items shown in pounds, as shown on the attached being used during the inspection. found to be in violation as only the notation [LBS] was The shipping document in use from the shipper (# 2) was shown over the column. However upon further inspection oI the shipping document you find Total Pieces: 2 Total Weight: 96lbs in the body of the bill. heading [LB51 over a column is correct or if a column with our concern is if a shipping document with just the [WEIGHT (1bs)] is correct, or if either are appropriate to to use. I appreciate your time and interest in this matter and Fax 864-487-5694. Mail to Overnite Transportation Company await your reply. I can be contacted at 864-489-1173 OF PO Box 246 Gaffney, 50 29342. Sincerely; Garry Howell Environmental supervisor GENERAL OFFICE / P. O. BOX 1216 / RICHMOND, VIRGINIA 23209 ** TOTAL PAGE.05**#