Overnite Transportation Company — Hazardous Materials Safety Interpretation

Page 1• of Transportatior J.S. Department 400 Seventh St., S.W. Washington, D.C. 20590 Research and Special Programs Administration OCT 1 6 2001 Mr. Garry Howell Reference No.: 01-0223 Overnite Transportation Company P. O. Box 246 Gaffney, SC 29342 Dear Mr. Howell: This is in response to your letter requesting clarification of the shipping paper requirements for ORM-D materials under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your questions are paraphrased and answered as follows: Q1. When a material is described as "Consumer commodity, ORM-D" on a shipping document, can the "X" be placed in the "HM" column and if so, is the entry required or optional? Al. Even though § 172.200 excepts a Consumer commodity, ORM-D material from the shipping paper requirements, except when offered or intended for transportation by air, it is permissible to place an "X" in the "HM" column on the shipping document. Q2. If a shipping document has an entry for a material that is not subject to the shipping paper requirements, is the emergency response telephone number, shipper certification and shipper signature required? A2. The answer is no. The requirements of Subpart G do not apply to a hazardous material that is excepted from the shipping paper requirements (see § 172.600(d)). I trust this satisfies your request. Sincerely, John A.(Gal Transportation Regulation Specialist Office of Hazardous Materials Standards • 010223 -#

Page 2OVERNITE TRANSPORTATION COMPANY * * P.O. BOX 246 / GAFFNEY, SC 29342 OVERNITE -*— SPORTAIN Cal Corbin $172.201 8/17/01 Shipping Papers 01-0223 Mr. Edward Mazullo 400 Seventh St, Director of Hazardous Material Standards Washington, DC 20590 Dear Mr. Mazullo: Richmond, Virginia requesting an interpretation in writing I am writing on behalf of Overnite Transportation Company on the following. When a description of on a shippers (Consumer Commodity ORM-D) is shown column of the shipping paper, and if so, would the X be bill of lading. Can the X be place in the H/M (required) or an (option). description, class, and X Second item of concern is if the shipper uses this excepted from the shipping paper requirements. Does this no in the H/M column , which ar telephone number, require the shipper to also show an emergency response signature. shippers certification, and shippers response. I appreciate your time in this matter and await your PO Box 246 Gaffney, SC Response dan be mailed to Overnite Iransportation Company 29342 Att; Garry Howell Singerely; A any Showill Garry Howell Environmental Supervisor - GENERAL OFFICE / P. O. BOX 1216 / RICHMOND, VIRGINIA 23209#