USCG TRACEN Yorktown (tmst) — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Ave, S.E. Washington, D.C. 20590 Mr. Kevin Henson Training Specialist (L3) USCG TRACEN Yorktown (tmst) End of State Route 238 Yorktown, VA 23690-5000 Reference No. 09-0040 Dear Mr. Henson: This is in response to your request for clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) regarding information required to be included on the dangerous cargo manifest. Specifically, you ask whether the subsidiary hazard class and the packing group must be included on the dangerous cargo manifest. The answer is yes. Section 176.30(a)(5) requires the classification of the hazardous material, which includes the subsidiary hazard class and the packing group, to be noted on the dangerous cargo manifest. The dangerous cargo manifest assures that information about the hazardous materials on board a vessel is readily available in a single document. As specified in $ 176.30(b), the hazardous material information on the dangerous cargo manifest must be the same as the information furnished by the shipper on the shipping order or other shipping document. The wording in 176.30(a) will be revised to provide clarification in an upcoming rulemaking. I hope this information is helpful. Please contact this office if you have additional questions. Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards#

Page 2Drakeford, Carolyn <PHMSA> From: Sent: To: Cc: Subject: Kelley, Shane <PHMSA> Thursday, February 19, 2009 12:58 PM Drakeford, Carolyn <PHMSA> Mclntyre, Joan <PHMSA> FW: interpretation of 49 CFR $176.3 0 4 172 ----- Original Message----- From: Henson, Kevin CTR Sent: Thursday, February 19, 2009 9:18 AM To: Bornhorst, Richard Cc: Sorge, Randy MSTCS; Foss, George CTR; Jolly, Danica MSTl Subject: interpretation of 49 CFR I am requesting a formal interpretation of the requirement to show subsidiary hazard class and packing group on the Dangerous Cargo Manifest (DCM). These entries are vague and would leave questions in enforcement. Possible fixes would just omit 176 and refer to IMDG or have it state the DCM will described each hazard as directed in 172.202 with the addition information required by 176. <i.e.. stowage location>. Kevin Henson Training Specialist (L3) USCG TRACEN Yorktown (tmst) End of State Route 238 Yorktown, Va 23690-5000 Phone: 757-856-3500 ext 3206 FAX : 757-856-2098 Email: Kevin.L.Henson@USCG.mil#