Horizon Lines, LLC — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration AUG 11 2010 1200 New Jersey Ave, SE Washington, D.C. 20590 Mr. Cliff Bartley Horizon Lines, LLC Blount Island 5800-1 William Mills Street Jacksonville, FL 32226 Ref. No.: 10-0140 Dear Mr. Bartley: This responds to your June 30, 2010 letter requesting clarification ofthe requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to shipping papers. Specifically, you ask ifthe shipping description for a hazardous material on a shipping paper may be hand-written in cursive writing. You provided an example of a basic description handwritten in cursive. The HMR require the shipping description on a shipping paper to be legible and printed (manually or mechanically) in English (see § 172.201). There is no restriction on the use of cursive handwriting when creating a shipping paper, as long as the text is legible and meets the requirements of § 172.201. Please note that the legibility ofhandwritten basic descriptions can vary significantly due to human factors. As a result, some written descriptions may not satisfy the legibility requirements of the HMR. Therefore, we recommend that shipping descriptions are printed mechanically, whenever possible, to avoid unnecessary delays or compliance issues. I hope this answers your inquiry. If you have further questions, please do not hesitate to contact this office. Sincerely, Ben Supko Acting Chief, Standards Development Office ofHazardous Materials Standards#

Page 2___________tl~~~~~~ Tuesday, June 30, 2010 Mr. Ed Mazzullo Director, Office of Hazardous Materials Standards U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration East Building, 2nd Floor Mail Stop: E21-317 1200 New Jersey Ave., SE Washington, DC 20590 Dear Mr. Mazzullo, I am writing to your department to request a formal interpretation of 49CFRl72.201(a)(2) as it pertain to the requirement that the hazardous material shipping paper be "legible and printed (manually or mechanically) in English". I have a few customers who prepare their hazardous materials documentation on a printed form but the hazardous information is recorded in cursive writing. I have had a policy of accepting this type of documentation since the cursive writing is legible and clear. In passing the information on to other parties in the transportation chain, there have been some reservations to the documentation stating that 'it was not in "English". The parties stated that, liThe other attachment is handwritten and in cursive so the USCG won't accept that". There does not seemto be a problem with the legibility of the text but the issue seems to be the cursive writing. Please confirm that c:'ursive English text is appropriate for the dangerous goods deelaration. An eXi;lmple oftheactual document is as follows. Thank you·for your time attentiQn to this matter.. Sincerely, f!4I6/~; ~Iiff Bartlev,·\L/?/' Horizon Lines, llC Manager Hazardous Materials Horizon Lines. Blount Island. 5800-1 William Mills Street. Jacksonville, FL 32226. 904.757.8266. wwwhorizon-linescom#