Gilmore Environmental Consulting, LLC — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration SEP 1 6 2010 1200 New Jersey Ave, SE Washington, D.C. 20590 Mr. John Thompson Gilmore Environmental Consulting, LLC 4 Vermont Square Edgewater Park, N J 08010-3123 Reference No. 10-0081 Dear Mr. Thompson: This is in response to your e-mail requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) regarding the use ofpunctuation marks. Specifically, you ask whether a hyphen is required between the words "Poison" or "Toxic" and the word "Inhalation" when the words "Poison Inhalation Hazard" or "Toxic Inhalation Hazard" are required by § 172.203(m) to be entered on the shipping paper following the basic description. The answer is no. The words can be entered with or without the hyphens. Also, for your infonnation, § 172.101(c)(2) cited in your e-mail is specific to proper shipping names as entered in Column (2) of the § 172.101 Hazardous Materials Table and specifies that punctuation marks are not part of the proper shipping name and may be used, but are not required. The words "Poison Inhalation Hazard" or "Toxic Inhalation Hazard" as specified in § I 72.203(m) are not part ofthe proper shipping name, but are required infonnation that follows the basic description. I hope this infonnation is helpful. Please contact this office should you have additional questions. Sincerely, ~F~-- T. Glenn Foster, Chief Regulatory Review and Reinvention Office of Hazardous Materials Standards#

Page 2Drakeford, Carolyn (PHMSA) From: INFOCNTR (PHMSA) Sent: Thursday, April 08,201010:59 AM To: Drakeford, Carolyn (PHMSA) Subject: letter of Interp Request -----Original Message----From: PHMSA-Feedback [mailto:PHMSA-Feedback] Sent: ThursdaYJ April 08 J 2010 10:26 AM To: PHMSA HM InfoCenter; PHMSA Webmaster Subject: Hazmat Information Center Feedback: Other Questions? in 172.101 (c)(2)it states Punctuation marks and words in italics are not part of the proper shipping name J but may be used. In 172.203 (m)it states the words "Poison-Inhalation Hazard or "Toxic-Inhalation Hazard"and the words Zone AJ 8J CJ or D shall be entered on the shipping paper immediately following the shipping description. I have a client that has an outside company provide a computered generated bill of lading. It does not have a hyphen between Poison or Toxic Inhalation and they have a customer that states there MUST be one there J Who is correct? Could I please get something in writing to show what is the correct way? Thank you. Name: John Thompson Organization: Gilmore Environmental ConsultingJ LLC Email: hazmatkingnj@comcast.net Address: 4 Vermont Square City: Edgewater Park Zip Code: 08010-3123 Phone: 609 877 3721 1#