# Fed Ex Freight — Hazardous Materials Safety Interpretation

- **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:** Not available
- **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:**

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U.S. Department
of Transportation
Pipeline and Hazardous
Materials Safety
Administration
1200 New Jersey Avenue, SE
Washington, D.C. 20590
Ms. Sandra Richesin
Ref. No. 08-00 15
Fed Ex Freight
P.O. Box 840
Harrison, AR 72602-0840
Dear Ms. Richesin:
This is in response to your letter requesting clarification of the Hazardous Materials
Regulations (HMR; 49 CFR Parts 1 7 1 - 180) pertaining to the shipper's certification
statement on shipping papers. You ask two questions pertaining to the signature that is
required for the statement. The questions are paraphrased and answered below.
Q1. A shipping paper includes a shipper's certification stathent as required by
172.204. If the shipping paper has one designated place for a signature, is any location
on the shipping paper acceptable for the signature that is required for the statement?
Al. Location of the signature anywhere on the same page as the certification statement
constitutes signing of the statement, provided the signature is not specifically assigned to a
statement not required by the HMR.
42. A shipping paper includes two designated places for signatures. One is specific to the
shipper's certification statement and the other is located elsewhere on the shipping paper.
The former is not signed; the latter is signed. Does this meet the requirements under the
HMR for the shipper's certification signature?
A2. You did not submit an example of the shipping paper in question. Because the
certification statement in this case includes a signature line specifically assigned to the
certification statement, leaving it unsigned may be confusing and may cause frustration of

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the shipment of hazardous materials. Although the HMR does not specify a location of the
signature on a shipping paper, reasonable care should be taken to format a shipping paper
that does not cause confusion.
I hope this information is helphl. If you have additional questions, please do not hesitate to
contact this office.
Sincerely,
Hattie L. Mitchell, Chief
Regulatory Review and Reinvention
OEce of Hazardous Materials Standards

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PO. Box &90 Harrison. AR 72602-0840 2200 Forward Orive
Halfison. AN 72601
Telephone 1.870.741.9000
Toll.Free 1.800.874.4723
Fax 1.810.741.3003
Freight
December 26,2007
Mt. John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards
U.S. DOT - PHMSA
1200 New Jersey Ave., S.E.
Washington, DC 20590
Dear Chief Gale,
This letter is a written request for interpretation of signature requirements for the
shipper's certification on the shipping paper as stated in 49CFR $172.204(d). I have two
questions, please. (1) If the shipping paper has one shipper signature area with a
signature and the shipper certification statement is printed on the shipping paper, does
that meet the requirement since there is no location requirement for the signature? (2) If
the shipping paper has a specific signature area with the shipper certification, and it is not
signed, yet there is another shipper signature area on the shipping paper and it is signed,
does that meet the requirement?
I appreciate your time in reviewing these questions and look forward to receiving your
response.
Sincerely,
Sandra Richesin, DER
Safety Compliance Administrator
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