{"operation":"document","citation":"02-0317","title":"Hobart Huson — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2003-01-23","effective_on":null,"summary":"02-0317 concerning 172.201.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0317.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0317.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-02-0317","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2002/020317.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nResearch and\nof Transportation\n400 Seventh St., S.W.\nWashington, D.C. 20590\nAdministratior\nspecial Program:\nJAN 2 3 2003\n220 Carolwood Drive\nMr. Hobart Huson\nRef. No. 02-0317\nSan Antonio, TX\n78213\nDear Mr. Huson:\nThis is in response to your letter dated December 6, 2002,\nconsisting of non-hazardous materials and hazardous materials\nconcerning the shipping paper requirements for a shipment\nunder the Hazardous Materials Regulations (HMR; 19 CER Parts\n171-180). \" Specifically, you ask if a non-hazardous material\nmust be described on a shipping paper in the same manner as a\nhazardous material when transported together as a mixed\nshipment.\nThe answer is no.\nof hazardous materials in commerce.\nThe HMR only apply to the transportation\npaper requirements in Part 172, Subpart C do not apply to a\n•Therefore, the shipping\nnon-hazardous material. However, a shipping paper that\ndescribes both hazardous materials and non-hazardous\n-materials must comply with $ 172.201 (a) (1).\nSincerely,\nOffice of Hazardous Materials\nRegulations Specialist\nStandards\n172.201\n020317\n\n<<<PAGE 2>>>\n\nBAH\nPage 1 of 1\n8112.201\nINFOCNTR\nFrom: Husons [husons@earthlink.net]\nShipping Papers\nSent: Friday, December 06, 2002 3:53 PM\n03 - 0317\nTo:\nInfocntr, Infocntr <RSPA>\nSubject: Nonhazardous Material Shipping Question\nDear Sirs,\nI was hoping your department could provide for me alletter of clarification regarding nonhazardous materials\nshipping.\nI used to run a laboratory chemical distributorship. We sold and shipped many different hazardous and non\nbeen implied that any nonhazardous material was not subject to the shipping documentation required of\nhazardous chemicals. Because the CFR 49 oniy describes the regulations of hazardous materials, it has long\nlading or other shipping documents when being shipped. Only hazardous materials are required to be listed with\nhazardous materials. Specifically, there is no DOT requirement that nonhazardous materials be listed on a bill of\ntheir appropriate DOT and UN information etc.\nI am currently in dispute with an agency that does not understand that when a nonhazardous material is shipped\nmaterials as we would with any other hazardous materials within the same shipment. This agency will not accept\nwith other hazardous materials, my company was under no obligation to include a listing of nonhazardous\nwithin the CFR 49. They require some proof on our part that this is more than an assumption of the rules.\nfor an answer that our assertion regarding nonhazardous materials may be merely implied by lack of instruction\nnonhazardous materials in shipping documentation as one would for hazardous materials? This would be greatly\nCan your department please provide for me some sort of verification that a company is not required to list\nappreciated!\nIn addition - more out of curiosity than necessity on my pait - it was my experience with shipping companies that\nwhen I would list all the various chemicals (both hazardous and ronhazardous) on the shipper bill of lading, we\nwould invariablv have our shipment halted or returned. The reason was that shipping personnel are not very\ntypically get a call from the shipper asking why we did not include the DOT and UN information for the other\nfamiliar with chemicals and they all of them sound dangerous and hazardous to the uninformed. We would\nchemicals (the honhazardous ones). Only after explaining the reason to the shipper would our shipments\navoid the problem. I do not know if you can comment on this as well, but is DOT aware of this kind of problem\ncontinue. It had been suggested to us by shippers to just leave off the nonhazardous materials in the future to\nand, in part, agree with this practice? I would hope you do. It would further help my situation.\nVery Truly Yours,\n220 Carolwood Drive\nMr. Hobart Huson\nTel: 210-340-5183\nSan Antonio, TX 78213\nemail: husons@earthlink.net\nFormer Business:\n1920 Treble Dive, Suite J1\nHumble, TX 78213\n12/6/02","truncated":false,"body_characters":3973}