Guidanceguidance
09-0237
Ecolab — Hazardous Materials Safety Interpretation
Current as of source date Government source
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Page 1U.S. Department ofTransportation 1200 New Jersey Avenue, SE Washington, DC 20590 Pipeline and Hazardous Materials Safety Administration DEC 2 2009 Mr. Stephen V. Schulte, CHMM, CPP, DGSA Director, Global Transportation Compliance Ecolab 370 Wabasha Street N St. Paul, MN 55102 Ref. No. 09-0237 Dear Mr. Schulte: This responds to your October 22, 2009 request for clarification of shipping paper requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if commonly used names of packagings may be used to satisfY the requirements in § 172.202(a)(7) to indicate the type ofpackaging on shipping papers. The answer is yes. Commonly used and recognizable names for a packaging, such as pail, box, drum, cylinder, and the like, may be used to describe the type ofpackaging on shipping papers under §172.202(a)(7) requirements. I hope this answers your inquiry. If you need additional assistance, do not hesitate to contact this Office. Sincerely, '~~~~ Charles E. Betts Chief, Standards Development ce ofHazardous Materials Standards#
Page 2ECOLAB® STEPHEN V. SCHULTE Director, Global Transportation Compliance T 651.293.4348 F 651.225.3122 l3oo-the. ~ Ill.. 2 D2(ti)('7j Shipp I OJ pqp er.s October 22, 2009 D9-0,.'31 Mr. Edward T. Mazzullo Director, Office of Hazardous Materials Standards Pipeline and Hazardous Materials Safety Administration U.S. Department of Transportation East Building, 2nd Floor 1200 New Jersey Ave., SE Washington, DC 20590 Re: Request Letter of Interpretation 49 CFR § 172.202(a)(7) - Type of Packaging Dear Mr. Mazzullo: This is a follow up to our conversation regarding the type of packages that must be indicated on shipping papers, manifests and bills of lading for hazardous materials in transportation. It is my understanding that any commonly referred to name, such as pail, box, drum, etc. may be used to satisfy the requirements of 49 CFR § 172.202(a)(7) and that it is not required to be a term used in 49 CFR § 173.201 - § 173.213. Sincerely, Stephen V. Schulte, CHMM, CPP, DGSA Director, Global Transportation Compliance 370 Wabasha Street N S1. Paul, MN 55102#
This material provides agency context. It does not replace binding regulatory text, and its legal effect depends on the underlying authority and facts.