{"operation":"document","citation":"08-0015","title":"Fed Ex Freight — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2008-02-21","effective_on":null,"summary":"08-0015 response to Fed Ex Freight concerning 172.204.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-08-0015.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-08-0015.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-08-0015","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2008/080015.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\nMs. Sandra Richesin\nRef. No. 08-00 15\nFed Ex Freight\nP.O. Box 840\nHarrison, AR 72602-0840\nDear Ms. Richesin:\nThis is in response to your letter requesting clarification of the Hazardous Materials\nRegulations (HMR; 49 CFR Parts 1 7 1 - 180) pertaining to the shipper's certification\nstatement on shipping papers. You ask two questions pertaining to the signature that is\nrequired for the statement. The questions are paraphrased and answered below.\nQ1. A shipping paper includes a shipper's certification stathent as required by\n172.204. If the shipping paper has one designated place for a signature, is any location\non the shipping paper acceptable for the signature that is required for the statement?\nAl. Location of the signature anywhere on the same page as the certification statement\nconstitutes signing of the statement, provided the signature is not specifically assigned to a\nstatement not required by the HMR.\n42. A shipping paper includes two designated places for signatures. One is specific to the\nshipper's certification statement and the other is located elsewhere on the shipping paper.\nThe former is not signed; the latter is signed. Does this meet the requirements under the\nHMR for the shipper's certification signature?\nA2. You did not submit an example of the shipping paper in question. Because the\ncertification statement in this case includes a signature line specifically assigned to the\ncertification statement, leaving it unsigned may be confusing and may cause frustration of\n\n<<<PAGE 2>>>\n\nthe shipment of hazardous materials. Although the HMR does not specify a location of the\nsignature on a shipping paper, reasonable care should be taken to format a shipping paper\nthat does not cause confusion.\nI hope this information is helphl. If you have additional questions, please do not hesitate to\ncontact this office.\nSincerely,\nHattie L. Mitchell, Chief\nRegulatory Review and Reinvention\nOEce of Hazardous Materials Standards\n\n<<<PAGE 3>>>\n\nPO. Box &90 Harrison. AR 72602-0840 2200 Forward Orive\nHalfison. AN 72601\nTelephone 1.870.741.9000\nToll.Free 1.800.874.4723\nFax 1.810.741.3003\nFreight\nDecember 26,2007\nMt. John A. Gale\nChief, Standards Development\nOffice of Hazardous Materials Standards\nU.S. DOT - PHMSA\n1200 New Jersey Ave., S.E.\nWashington, DC 20590\nDear Chief Gale,\nThis letter is a written request for interpretation of signature requirements for the\nshipper's certification on the shipping paper as stated in 49CFR $172.204(d). I have two\nquestions, please. (1) If the shipping paper has one shipper signature area with a\nsignature and the shipper certification statement is printed on the shipping paper, does\nthat meet the requirement since there is no location requirement for the signature? (2) If\nthe shipping paper has a specific signature area with the shipper certification, and it is not\nsigned, yet there is another shipper signature area on the shipping paper and it is signed,\ndoes that meet the requirement?\nI appreciate your time in reviewing these questions and look forward to receiving your\nresponse.\nSincerely,\nSandra Richesin, DER\nSafety Compliance Administrator","truncated":false,"body_characters":3276}