Landstar Carrier Services — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation 400 Seventh St., S.W. Research and Washington, D.C. 20590 Administration Special Programs MAR 12 2004 Mr. Wes Pace Landstar Carrier Services Hazmat Compliance Manager Ref. No. 03-0324 13410 Sutton Park Dr. S. Jacksonville, F1 32224 Dear Mr. Pace: This is in response to your letter dated December 19, 2003, regarding the proper description of hazardous materials on a shipping paper required under the Hazardous Materials Regulations (HMR; 49 CPR Parts 171-180). Specifically, you ask whether an "X" in the HM column where there is no "basic description" listed or where additional information begins prior to the basic description would be permissible under § 172.201 of the HMR. The answer is no. The hazardous material entries must be clearly and readily identifiable when description consisting of the proper shipping name, hazard class, identification number, and described on the same shipping paper with materials not subject to the HMR. The basic packing group, must be shown in proper sequence, as required in § 172.202 (a) and (b). As shipping name. Any additional information required by § 172.203 must be placed after the basic stated in § 172.201(a)(1)(iii), the "X'" must be placed in the HM column before the proper description, unless otherwise permitted. The number and type of packaging, total quantity shipped, and destination marks are the only entries permitted to precede the basic description and may be repeated after the basic description. The required shipping description may not contain any code or abbreviation, unless specifically authorized. A shipper's certification statement must appear on the shipping paper as required by § 172.204. We trust this satisfies your request. Please contact us if we can be of more assistance. Sincerely, Hitle z. Michel Hattie L. Mitchell, Chief Regulatory Review and Reinvention Office of Hazardous Materials Standards 112.201 030324#

Page 2UCTIO LANDSTAR 3|72.201 (a) (ill) Compliance Shipping Papers 03-0324 12/19/03 Edward Mazzula Office of Hazardous Materials Standards Room 8422 Washington, D.C. 20590 Mr. Mazzula, I'm seeking a clarification on 172.201 (a)(iii) and specifically, if it's permissible to have in "X" in the HM column where there is no "basic description" listed and secondly if it' basic description. ermissible to have an X in the HM column where additional info begins vs. the actua An example would be government bill of ladings (CBL)(enclosed) that uses multiple their cover page, they will have a notation in the description column that states this bill pages and typically has all commodities listed on pages other than the cover page. On bill consist of. They have an "X" in the HM column (on the cover page) where there is consist explosives or ammunition etc. (no basic description) and the number of pages the no basic description listed. Please clarify that by placing an "X" in the HM column where there is no "basic description" listed, would not be permissible per the regulations as well as having an "X" in the HM column where additional info begins prior to the basic description. Your written opinion and comments are appreciated Wes singers bee Wes Pace Landstar Carrier Services Hazmat Compliance Manager 13410 Sutton Park. Dr. S. Jacksonville, FI. 32224 Serving Landstar Express America • Landstar Gemini • Landstar Inway • Landstar Ligon • Landstar Ranger P. O. Box 19135 Jacksonville, Florida 32245-9914#