Emery Forwarding — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Washington, D.C 400 Seventh Street. SW 20590 Research and Special Programs Administration NOV 12 2002 Mr. Tom Vranesic. Ref. No. 02-0262 Emery Forwarding One Emery Plaza Vandalia, OH 45377 Dear Mr. Vranesic: This is in response to your letter dated September 24, 2002, requesting clarification of the requirement to place the date of acceptance on a shipping paper. Specifically, you ask if a shipping paper that includes a copy of the Internatiohal Air Transport Association's (IATA's) air acceptance checklist, a checklist that contains the date of acceptance, would meet § 175.30(a)(2) of the Hazardous Materials: "Regulations (HMR; 49 CFR Parts 171-180): IATA Dangerous Goods Regulations do not have official standing under the HMR. The requirement found in § 175:30(a)(2) states that each shipping paper must inèlude the date of acceptance by the initial carrier. Provided your shipping paper conforms to the réquirements of Part 172, Subpart C, including the requirements for continuation pages found in § 172.201(c), the air acceptance checklist portion you describe will fulfill the date of acceptance requirement contained in § 175.30(a)(2). I hope this satisfies your iriquiry. If we can be of further assistance, please contact us. Sincerely, Silm Faili Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 175.30 020262#

Page 2.... EMERY September 24, 2002 Chief, Standards Development Mr. Delmer F. Billings BAH Office of Hazardous Materials Standards $175.30 Shipping Papers Dear Mr. Billings, 02-0262 I'm writing to you seeking clarification of the "date of acceptance" component of the revisions to 49CFR 175.30(a)(2). As a forwarder primarily accepting recording date of acceptance is to attach a copy of the air acceptance checklist, which we dangerous goods shipments for air transport under IATA/ICAO, our current method of consider part of the shipping paper, to the Shipper's Declaration. Each checklist is dated With the actual date of acceptance and accompanies the shipment throughout the transportation cycle. Shipper's Declaration, in the Additional Handling Information section. Per IATA Some carriers have indicated that the date of acceptance must be recorded on the Dangerous Goods Regulations, the only entries permitted in this section are entries relating to the handling of the shipment. Additionally, entries in this section must only be made by the shipper. sufficient to comply with the regulation. If not, please advise alternative methods for Please advise if our current method satisfies the intent of the regulation and is satisfying the requirements while still complying with IATA regulations. Sincerely, Tom Vranesic Senior Analyst, Dangerous Goods : 09:. :?. Lossy Forwarding One Enemies, Pandelie ON ASH:#