Cerasis 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 JAN 3 0 2009 Mr. Frank Adams Cerasis Inc. 3200 Courthouse Lane Eagan, MN 55 121 Reference No. 08-0280 Dear Mr. Adams: This is in response to your electronic transmission requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) pertaining to shipping description requirements for bills of lading (shipping papers). Specifically, you ask whether both the shipping description requirements in 5 172.202 and the National Motor Freight Classification (NMFC) freight class description must be included on the shipping paper and whether it is acceptable to print the NMFC number and associated class for the hazardous material in a separate, specified field on the shipping paper. Sections 172.202 and 172.203 specify the requirements for information that must be included on shipping papers, which includes the proper shipping name prescribed for the material in Column (2) of the 5 172.101 Hazardous Materials Table. The HMR do not require the NMFC number and associated class to be included on the shipping paper. Additional information that is not required by the HMR, such as the NMFC number and associated class, may be included in a separate field on the shipping paper provided it is not interspersed in the required elements of the basic description (proper shipping name, hazard class/division number, identification number and packing group, if applicable) (see 5 172.202(b)), is not inconsistent with the required basic description and is entered after the basic description (see 5 172.201(a)(4)). I hope this information is helpful. Please contact this office if you have additional questions. Sincerely, Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards#

Page 2Drakeford, Carolyn <PHMSA> From: Sent: To: Subject: INFOCNTR <PHMSA> Monday, November 17,2008 9:54 AM Drakeford, Carolyn <PHMSA> FW: Interpretations (Letters) issued by PHMS ----- Original Message----- From: PHMSA-Feedback [mailto:PHMSA-Feedback] Sent: Friday, November 14, 2008 4:00 PM To: PHMSA Web Initiative Subject: Interpretations (Letters) issued by PHMS Please furnish an Interpretation Letter/Email Is it required that both the Hazmat Descriptions (172.202)AND the NMFC freight class descriptions appear on the Bill of Lading for a given item shipped? OR can we print just the Hazmat 172.202 descriptions and print the NMFC number and associated class in their appropriate BOL column/ f ields? Regards, Frank Adams Name: Frank Adams Organization: Cerasis Inc. Email: fadams@cerasis.com Address: 3200 Courthouse Lane City: Eagan Zip Code: 55121 Phone: (651) 365-8143 FAX: (651) 365-8157#