Air Products and Chemicals, Inc. — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Depanment 400 Seventh St., S.W. Research and SEP 27 2004 Washington, D.C. 20590 Administration Special Programs Ms. Genette Fields-Smith Air Products and Chemicals, Inc. Ref. No. 04-0207 7201 Hamilton Boulevard Allentown, PA 18195-1501 Dear Ms. Fields-Smith: This is in response to your September 3, 2004 letter requesting clarification of SS 172.201 and 177.817 (e) of the Hazardous Materials the shipping paper requirements contained in Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if you may use on-board vehicle computing devices to maintain electronic versions of shipping papers, in place of hard copies of shipping papers, while in transit. The answer is no. Electronic versions of the shipping papers, including those in devices that allow viewing on a computer screen or printing of a paper copy, are not acceptable as shipping papers while in transportation. When in transportation, a shipping paper must be legible and printed (manually or mechanically) in English (§ 172.201 (a) (2)). I hope this information is helpful. If you have further questions, please do not hesitate to contact this office. Sincerely, Trikes Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards $172.201 $177.817(e)2) 040207#

Page 295100/ BAH $/72.201 PRODUCIS E: $ 177.817 (e)z) Air Products and Chemicals, inc. Allentown, PA 18195-1501 7201 Hamilton Boulevard Shipping Papers Telephone (610) 481-4911 04-0207 Office of Hazardous Materials Standards Edward T. Mazullo, Director US DOT/RSPA (DHM-10) 400 7 Street SW Washington, DC 20590-0001 Request for Written Interpretation Regarding Shipping Paper Preparation and Accessibility - 49 CFR 172.201 and 177.817(e)(2) Dear Mr. Mazullo: Currently, Air Products and Chemicals' commercial motor vehicle operators use automatic on-board computing devices to satisfy 49 CFR requirements. A new generation of the following capabilities: device is under construction and if permitted by the regulation, the device would have the a. Display required shipping paper information as listed in 172.201; c. Within the drivers immediate reach while he is restrained by the lap belt; b. Readily available and recognizable in the event of an accident or inspection; •. Placed on the driver's seat in the vehicle when the driver is not at the vehicle's d. Readily visible to a person entering the driver compartment; and Are companies prohibited from using an automatic on-board computing device (in lieu of the hard copy shipping paper) when meeting the requirements of 172.201 and 177.817(e)(2)? interpretation is necessary and greatly appreciated. You may contact me at 610.481.7754 if As project completion quickly approaches, your expeditious response for a written you have questions. Respectfully, Benette trades Smith Genette Fields-Smith Air Products and Chemicals, Inc Regulatory Specialist#