# Myers Industries, Inc. — Hazardous Materials Safety Interpretation

- **operation:** document
- **citation:** 03-0247
- **title:** Myers Industries, Inc. — Hazardous Materials Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 2003-10-21
- **effective on:** Not available
- **summary:** 03-0247 response to Myers Industries, Inc. concerning 172.202.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-interpretation-03-0247.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-03-0247.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-03-0247
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2003/030247.pdf
**body:**

<<<PAGE 1>>>

400 Seventh St., S.W.
Washington, D.C. 20590
esearch an
ост 2 1 2003
Ms. Barb Germano
Safety & Risk Administrator
Ref. No. 03-0247
Myers Industries, Inc.
1293 South Main Street
Akron, OH 44301
Dear Ms. Germano:
This is in response to your October 6, 2003 letter, concerning shipping papers under the
Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your questions are
paraphrased and answered as follows:
Q1.
Must a driver create a new shipping paper or revise an existing shipping paper to reflect
partial delivery of a product? For example, a driver transports ten drums and only
delivers two. Must he change the shipping paper to indicate that he has only eight drums
on the transport vehicle?
Al.
The answer is no. A driver is not required to update a shipping paper to reflect partial
delivery. However, if a driver picks up additional quantities of hazardous materials,
which were not previously indicated on the shipping paper, the additional quantities must
be added it the total quantity on the vehicle exceeds that indicated on the shipping papers.
Q2.
Is a driver required to present a shipping paper to the consignee of a hazardous material
upon deliver to the consignee's cite?
A2.
The answer is no. Each person who offers a hazardous material for transportation shall
describe that hazardous material on the shipping paper and present it to the carrier.
I hope this satisfies your request.
Sincerely,
Transportation Regulations Specialist
Office of Hazardous Materials Standards
030247
172,202

<<<PAGE 2>>>

OCT 06 03 04:26 FR RISK-MGMT
330 761 6247 TU 12023553012
P.01
BAHt
Fax Memo
§172.202
Shipping Papers
DATE: 10-6-03
03-0247
TO:
EDWARD MAZZULLO, DIRECTOR OF HAZARDOUS
MATERIALS STANDARDS
FROM: BARB GERMANO
RE:
Bills of Lading for Haz Mat shipments
FAX:
1-202-366-3012
Our company has a delivery van which is stocked like a mini warehouse. He leaves
our location in the morning with a bill of lading showing the van is stocked with 10
each 5-gallon pails of Adhesives.
The driver stops at various customers throughout the day.
As he makes his stops at the various customers, he may sell 2 pails of the Adhesives
throughout the day.
My questions are:
1. After selling 2 pails of the Adhesives, his original bill of lading will still show 10
pails, even though he has sold 2 pails. Does he have to complete a new bill of
lading to show what is now in his van?
2. When he sells the 2 pails of Adhesives to a customer, does he have to present the
customer with a bill of lading showing he delivered the Adhesives?
Also, if we sell 6 different hazardous products, can we have a preprinted bill of
lading showing all 6 products and fill in the appropriate line when we ship 1 of the
products?
Could you please respond in writing?
Thank you,
Barb Germano
Phone: 330-253-5592, Fax: 330-761-6247, E-Mail: bgermano@po.myersind.com
From: Barb Germano, Myers Industries, 1293 S Main St, Akron, Oh 44301
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