Guidanceguidance
07-0196
The Shepherd Chemical Company — Hazardous Materials Safety Interpretation
Current as of source date Government source
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Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, D.C. 20590 NOV 1 9 2007 Mr. Bayard Pelsor EHS Manager The Shepherd Chemical Company 4900 Beech Street Norwood, Ohio 45212 Ref. No. 07-0196 Dear Mr. Pelsor: This is in response to your e-mail asking whether the abbreviation "TT" is acceptable under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) for representing a cargo tank when indicating the packaging type on shipping papers. You point out that the U.S. Environmental Protection Agency (EPA) authorizes the abbreviation for hazardous waste manifests. In a follow-up telephone conversation with a member of my staff you asked whether "TT" would be an acceptable abbreviation on shipping papers for hazardous materials that do not require a hazardous waste manifest. The answer is yes. The abbreviation "TT" is a commonly accepted and recognizable abbreviation for cargo tanks (tank trucks) and, thus, may be used to indicate a shipment's packaging type on shipping papers in accordance with 5 '172.202 (a)'(6) of the HMR. I hope this information is helpful. Please contact this office should you have additional questions. Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards#
Page 2From: INFOCNTR <PHMSA> Sent: Friday, October 05, 2007 3:58 PM To: Drakeford, Carolyn <PHMSA> Subject: FW: Request for interpretation Wants a written interp. Thanks, Rob From: Bayard Pelsor [mailto:bpelsor@shepchern.com] Sent: Friday, October 05, 2007 11:58 AM To: TNFOCNTR < PHMSA> Cc: Jennifer Brown Subject: Request for interpretation U.S. Dept of Transportation - Information Center This is a request for interpretation. 49 CFR 172.202(a)(7) states that abbreviations may be used on shipping papers for indicating packaging types provided the abbreviations are commonly accepted and recognizable. Is ""TT" an acceptable abbreviation for "Cargo Tank"? It is listed on the back of U.S. EPA's Form 8700-22 Uniform Hazardous Waste Manifest as an acceptable abbreviation. Thank you. Bayard Pelsor EHS Manager The Shepherd Chemical Company 4900 Beech Street, Norwood, Ohio 45212 Phone: 51 3-458-6847 Fax: 51 3-731-21 51 Cell: 51 3-200-7453 Email: bpelsor@shepchem.com#
This material provides agency context. It does not replace binding regulatory text, and its legal effect depends on the underlying authority and facts.