{"operation":"document","citation":"10-0140","title":"Horizon Lines, LLC — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2010-08-11","effective_on":null,"summary":"10-0140 response to Horizon Lines, LLC concerning 172.201.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-10-0140.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-10-0140.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-10-0140","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2010/100140.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department of Transportation\nPipeline and Hazardous Materials\nSafety Administration\nAUG 11 2010\n1200 New Jersey Ave, SE\nWashington, D.C. 20590\nMr. Cliff Bartley\nHorizon Lines, LLC\nBlount Island\n5800-1 William Mills Street\nJacksonville, FL 32226\nRef. No.: 10-0140\nDear Mr. Bartley:\nThis responds to your June 30, 2010 letter requesting clarification ofthe requirements in the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to shipping papers.\nSpecifically, you ask ifthe shipping description for a hazardous material on a shipping paper\nmay be hand-written in cursive writing. You provided an example of a basic description handwritten\nin cursive.\nThe HMR require the shipping description on a shipping paper to be legible and printed\n(manually or mechanically) in English (see § 172.201). There is no restriction on the use of\ncursive handwriting when creating a shipping paper, as long as the text is legible and meets the\nrequirements of § 172.201. Please note that the legibility ofhandwritten basic descriptions can\nvary significantly due to human factors. As a result, some written descriptions may not satisfy\nthe legibility requirements of the HMR. Therefore, we recommend that shipping descriptions\nare printed mechanically, whenever possible, to avoid unnecessary delays or compliance issues.\nI hope this answers your inquiry. If you have further questions, please do not hesitate to contact\nthis office.\nSincerely,\nBen Supko\nActing Chief, Standards Development\nOffice ofHazardous Materials Standards\n\n<<<PAGE 2>>>\n\n___________tl~~~~~~\nTuesday, June 30, 2010\nMr. Ed Mazzullo\nDirector, Office of Hazardous Materials Standards\nU.S. Department of Transportation\nPipeline and Hazardous Materials Safety Administration\nEast Building, 2nd Floor\nMail Stop: E21-317\n1200 New Jersey Ave., SE\nWashington, DC 20590\nDear Mr. Mazzullo,\nI am writing to your department to request a formal interpretation of 49CFRl72.201(a)(2) as it pertain\nto the requirement that the hazardous material shipping paper be \"legible and printed (manually or\nmechanically) in English\".\nI have a few customers who prepare their hazardous materials documentation on a printed form but the\nhazardous information is recorded in cursive writing. I have had a policy of accepting this type of\ndocumentation since the cursive writing is legible and clear. In passing the information on to other\nparties in the transportation chain, there have been some reservations to the documentation stating\nthat 'it was not in \"English\". The parties stated that, liThe other attachment is handwritten and in cursive\nso the USCG won't accept that\".\nThere does not seemto be a problem with the legibility of the text but the issue seems to be the cursive\nwriting.\nPlease confirm that c:'ursive English text is appropriate for the dangerous goods deelaration. An eXi;lmple\noftheactual document is as follows.\nThank you·for your time attentiQn to this matter..\nSincerely,\nf!4I6/~;\n~Iiff Bartlev,·\\L/?/'\nHorizon Lines, llC\nManager Hazardous Materials\nHorizon Lines. Blount Island. 5800-1 William Mills Street. Jacksonville, FL 32226. 904.757.8266. wwwhorizon-linescom","truncated":false,"body_characters":3161}