Idaho State Police — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration MAY 7 6 2008 1200 New Jersey Avenue, SE Washington, D.C. 20590 Mr. Jim Eavenson Idaho State Police P.O. Box 700 Meridian, ID 83680-0700 Ref. No. 08-0087 Dear Mr. Eavenson: This responds to your March 20,2008 letter requesting clarification of the requirements for shipping papers under the Hazardous Materials Regulations (HMR; 49 CFR Parts 17 1 - 180). Specifically, you ask whether $ 172.202(a)(7), which requires an indication of the number and type of packages on a shipping paper, applies to both bulk and non-bulk packagings. The answer is yes. Section 172.202(a)(7) applies to both non-bulk and bulk packagings. I hope this information is helpful. Please contact us if you require additional assistance. [ Office of Hazardous ater rials Standards#

Page 2Idaho State Police Service since 1939 Colonel G. Jerry Russell Director C.L. "Butch" Otter Governor March 20, 2008 Mr. Edward T. Mazzullo Director, Office of Hazardous Materials Standards U.S. DOTIPHMSA 1200 new Jersy Avenue, SE East Building, 2nd Floor Washington, DC 20590 Dear Mr. Mazzullo, Please clarify 49 CFR 172.202(a)(7). Does this section only apply to non-bulk shipments or does it apply to both bulk and non-bulk? The examples listed are non-bulk examples, but there is nothing in the section excluding bulk shipments. The section says: 172.202(a)(7) The number and type of packages must be indicated. The type of packages must be indicated by description of the package (for example, "12 drums"). Indication of the packaging specification number ("1H1") may be included in the description of the package (for example, "12 1H1 drums" or "12 drums (UN 1Al)"). Abbreviations may be used for indicating packaging types (for example, "cyl." for "cylinder") provided the abbreviations are commonly accepted and recognizable. I have officers who contend this section applies to both bulk and non-bulk shipments. I have a carrier who contends it only applies to non-bulk. I called the HMIC and was told by two different technicians that the section applies to both, but they were unwilling to provide a written answer on this topic. Please send me a written answer to this question. Sincerely, Jim Eavenson Hazmat Sergeant, Idaho State Police P.O. Box 700 Meridian, ID 83680-0700 P.O. Box 700, Meridian, Idaho 83680-0700 EQUAL OPPORTUNITY EMPLOYER#