URS Corporation — Hazardous Materials Safety Interpretation

Page 1.S. Departmen f Transportatior 400 Seventh St., S.W. Research and Washington, D.C. 20590 special Programs Administration OCT 2 2 2003 Mr. Andrew N. Romach URS Corporation Ref. No. 03-0258 Morrisville, NC 1600 Perimeter Park Drive 27560 Dear Mr. Romach: This is in response to your letter dated October 8, 2003 concerning the requirement for the shipper's certification 171-180). under the Hazardous Materials Regulations (HMR; 49 CFR Parts. certification may be signed with a company name. Specifically you asked whether a shipper's The answer is no. The shipper's certification specified in partner, or $ 172.204 must be legibly signed by a principal, officer, ($172.204 (d)). employee of the shipper or his agent I hope this satisfies your request. Sincerely, John (office Of Hazardous Materials Standards Transportation Regulations Specialist 172,204 030258#

Page 2FROM: URS CORP FAX NO.: 9194611311 10 15 03:487 URS BAH 5172.204 6) October 8, 2003 Shipping Papers 03-8258 Mr. Ed Mazzullo, Director Office of Hazardous Material Standards esearch and Special Programs Administratic 400 7th Street. SW S. Department of Transportati Washington, DC 20590-0001 FAX: (202) 366-3012 Dear Mr. Mazzullo: I am writing to you to request a written regulatory interpretation concerning an acceptable shipper's certification on a hazardous material bill oflading. Does DOT accept the mechanically generated name of the company as the shipper's certification? 49 CFR 172.204(a) states that "each person who offers a hazardous material fur transportation shall cortify that the material is offered in accordance with this subchapter by printing (manually or mechanically) on the shipping paper containing the required shipping description the certification...." firm, copartnership, corporation, company.... that transports a hazardous material to further a The definition of person found in 49 CFR 171.8 rcads as follows: "Person means an individual, commercial enterprise or offers a hazardous maicrial for transportation in commerce...." Because the definition of "Person" includes a company as well as an individual, and because 49 generated name of the company (rather than an individual's name representing that company) CFR 172.204(a) allows a mechanically generaled signature, it appears to me that the mechanically would be an acceptable shipper's certification. I would appreciate your clarification of this question. Andrew N. Romach Regulatory Manager URS Corporation URS Corporation Morrisville, NC 27560 1600 Perimeter Park Drive Fax:919.461.1371 Tel: 919.461.1220 Andy_romach@urscorp.com#