{"operation":"document","citation":"07-0188","title":"Sun Chemical Corporation — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2007-11-05","effective_on":null,"summary":"07-0188 response to Sun Chemical Corporation concerning 172.202.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-07-0188.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-07-0188.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-07-0188","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2007/070188.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nNOV 5 2007\nMs. Amy Fishchesser\nSun Chemical Corporation\n5020 Spring Grove Avenue\nCincinnati, OH 45232\nRef. No. 07-01 88\nDear Ms. Fishchesser:\nThis responds to your September 26,2007 letter requesting clarification of the shipping paper\nrequirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 17 1-1 80).\nSpecifically, you ask whether the following abbreviations are acceptable for compliance with\nthe requirement to list the type of package(s) on a shipping paper:\nPackage Tvve Abreviation\nTote TOTE\nDnun DR\nPail PL\nBoxes BOXES\nSection 172.202(a)(7) requires the number and type of packages to be indicated on a shipping\npaper. That section permits the use of abbreviations to indicate package type provided the\nabbreviations are commonly accepted and recognizable. It is the opinion of this office that\nthe package type abbreviations that you provided in your letter are both commonly accepted\nand recognizable and are acceptable for describing the type of package(s) on a shipping\npaper.\nI hope this information is helpful. Please contact us if you require additional assistance.\nSincerely,\nChief, Standards Development / Ofice of Hazardous Materials Standards\n\n<<<PAGE 2>>>\n\nDrakeford, Carolyn <PHMSA> From:\nSent:\nTo:\nSubject:\n312; o o h 0\nt k ~ e ~\nINFOCNTR <PHMSA>\nThursday, September 27, 2007 2:50 PM\n~rakefoid, carolyn <PHMSA>\nFW: Information Center Comments/Questions\nCarolyn,\nCould you process this as a formal request for interpretation? Thanks.\nErin\n----- Original Message-----\nFrom: amy.fischesser@na.sunchem.com [mailto:amy.fischesser@na.sunchem.corn]\nSent: Wednesday, September 26, 2007 4:28 PM\nTo: INFOCNTR <PHMSA>\nSubject: Information Center Cornments/Questions\nBelow is the result of your feedback form. It was submitted by Amy Fischesser\n(amy.fischesser@na.sunchem.com) on Wednesday, September 26, 2007 at 16:27:45.\nName: Amy Fischesser\nCategory: Hazardous Materials Table, Special Provisions, Hazardous Materials\nCommunications\nOrganization: Sun Chemical Corporation\nStreet: 5020 Spring Grove Avenue\nCity: Cincinnati\nState: Ohio\nZip Code: 45232\nPhone: 513.484.7657\nFax: 513.632.1531\nComments: RE: 172.202(a)(6)requesting clarification.\nSun Chemical ships our hazmat in totes, drums; pails, boxes. When we ship we descibed as\nfollows: (e.9.) 2 TOTE; 3 DR; 2 PL; 2 BOXES. Wilson Trucking has advised Sun Chemical\nthat we have to say 2 IBC; 2 DRUMS. They said that Tote; DR & PL are not acceptable\nterminology and abbreviations.\nThe gentleman I spoke with at Wilson Trucking (Ron Maxey) said he attended a PHMSA class\nin May in Raleigh, NC and Jack Witley from PHMSA said that totes had to be referred to as\nIBCs and that the abbreviation DR was unacceptable and had to be spelled out as \"DRUM\".\nI talked with Mike Stevens on the DOT Hotline and he said Sun was not out of compliance --\nwe are okay with how we are describing our packaging. He said that as long as the\ntrucking company/carrier is clear as to what they are accepting and a DOT inspector would\nbe, we were okay.\nHowever, Wilson Trucking will not accept this conversation I had with Mike Stevens.\nI would appreciate clarification on what is acceptable and what is not acceptable. If Sun\nI\n\n<<<PAGE 3>>>\n\nI\nI must use the term IBC instead of Tote, this will involve a major computer change\n0 Thank you very much for your assistance.\nAmy Fischesser\nCorporate Hazardous Goods Transportation Manager Sun Chemical Corporation","truncated":false,"body_characters":3571}