Hawkins, Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Ave., SE Washington, DC 20590 Mr. Chris W. Gibson EHS&R Manager Hawkins, Inc. 3 100 East Hennepin Avenue Minneapolis, MN 5541 3 Reference No. 08-0 1 34 Dear Mr. Gibson: This is in response to your letter asking for clarification of requirements for a multi-page shipping paper under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171 - 180). You state your company receives orders for hazardous materials at different times from the same customers and creates a new shipping paper for each order. As a result, your drivers sometimes deliver several orders to the same customer with different shipping documents. You ask us to assume the emergency response telephone numbers, shipper certification statements and signatures, and net and/or gross weights of the materials are identical. We paraphrased your questions and answered them in the order provided. We apologize for the delay in responding and regret any inconvenience this may have caused. Ql . Must a multi-page shipping paper comply with § 172.201 (c)? A1 . Yes. Under 5 172.20 1 (c), a shipping paper may consist of more than one continuation page if each page in the shipping paper is numbered and the first page has a notation specifying the total number of pages, e.g., "Page 1 of 4 pages." However, individual shipping papers are not considered a multi-page shipping document under the HMR. Q2. Must a multi-page shipping paper have only one signed shipper certification statement under 8 1 72.204?#

Page 2A2. Yes, only one signed certification statement is required for a multi-page shipping paper. This signed certification can appear on the first or top page of the multi-page shipping paper. Also, please note placing the signature anywhere on the same page as the certification statement constitutes signing the certification. I hope this information satisfies your request. Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards#

Page 3May 12,2008 Mr. Edward T. Mazzullo Director, Office of Hazardous Materials Standards U. S. DOTIPHMSA (PHH- 10) 400 7th Street S.W. Washington, D.C. 20590-0001 URGENT REQUEST FOR INTERPRETATION RE: 49 CFR 172.201(c) and 172.204 Dear Mr. Mazzullo: We are seeking to clarify the differences between a multiple-page shipping paper and a series of individual shipping papers, which are going to the same delivery location. Assuming that each page has identical elements with regards to emergency response telephone numbers, shipper certifications, netlgross weights, etc, the only difference that we have been able to determine are: 1. Multiple page shipping papers are required to comply with 172.20 l(c), and 2. Multiple page shipping papers are required to have only one (I) shipper certification signature, per 172.204. Do you concur with these determinations? If you have any questions, I can be reached at 612-33 1-6910, x8551 or at chris.Gibson(~hawkinsinc.com Thank you. Sincerely, Chris W. Gibson EHS&R Manager Hawkins, Inc.#