Landstar Carrier Services — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, D.C. 20590 GEC 0 7 2087 Mr. Wes Pace Landstar Carrier Services 1341 0 Sutton Park Drive South Jacksonville, FL 32224 Ref. No. 07-0 18 1 Dear Mr. Pace: This is in response to your letter requesting clarification of the shipping paper requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 17 1-1 80). Specifically, you ask for the meaning of the wording "in association with" as it applies to the placement of additional information relative to the basic shipping description. You also ask whether the term "Residue: Last Contained" must be placed before the basic shipping description for packages other than tank cars, or is it permissible to place the term either before or after the basic shipping description. The wording "in association with the basic description" as it applies to additional, non-required information generally means "following the basic description." However, in the context of § 172.203(e)(l), the wording "in association with" means that the phrase "Residue: Last Contained * * *" may either precede or follow the basic shipping description for a package other than a tank car. As evidenced by the asterisks following "Residue: Last Contained in 172.203(e)(l), our preference is that the phrase "Residue: Last Contained" precede the basic shipping description on a shipping paper for a package other than a tank car that contains the residue of a hazardous material. As stated in § 172.203(e)(2), the phrase "Residue: Last Contained" must precede the basic shipping description when the residue is transported in a tank car. I hope this information is helpful. Please contact this office if you have additional questions. Sincerely, i Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards#

Page 2Mr. Edward T. Mazzullo Director, Off~ce of Hazardous Materials US DOTPHMS A (PHH- 10) 1200 New Jersey Avenue, SE East Building, 2" Floor Washington, DC 20590 September 5,2007 Mr. Mazzullo, Could your office please clarify the term "in association with" as it pertains to shipping descriptions on a shipping paper? Based on existing interpretation letters answered by your office, when additional information is used as part of a shipping description it may be placed "in association with" the description. One interpretation letter (#O1-0020) gives the definition of "in association with" as to mean "That the component may follow the basic description of the hazardous material". Some may interpret this wording as an option as to placement. Example: Empty Bulk packages being shipped by highway with a shipping description of: Residue, last contained Chlorine, 2.3,(8), UN1017 Poison-Lnhalation Hazard Zone B , Marine Pollutant In the scenario above, "Residue, last contained" is not required but permissible per 172.203(e)(1) and if used would be placed in association with the description. If the notation "Residue last contained" was used (other than a Tank Car shipments), must it be placed after the basic description and not before or is either placement pennissible? Your assistance in clarifying this would be most appreciated. Thanks Wes Pace Director, Hazardous Materials And Trade Compliance P- 904-390-48 1 5 F- 888-345-9220 Toll free- 800-235-7032 Email-wpace@landstar.com#