FedEx Freight, Inc. — 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 JUN 0 6 2013 Ms. Sandra Richesin Safety Compliance Specialist Mr. Mike Brust Corporate Safety FedEx Freight Inc. 2200 Forward Drive P.O. Box 840 Harrison, AR 72602-0840 Reference No. 13-0046 Ms. Richesin and Mr. Brust: This is in response to your e-mail requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR 171-180) applicable to shipping papers. Specifically, you ask about the proper placement of the type of packaging (i.e.; "BOX") on a shipping paper. The format of the shipping paper as shown in your e-mail is as follows: PCS HM DESCRIPTION WGT/Ibs X BOX,UN2790,ACETIC ACID SOLUTION,8 26 PGII You state that the word "BOX" is located in front (to the left) of the hazardous material basic description and ask whether this is in conformance with the requirements specified in § 172.202, "Description of hazardous material on shipping papers." The number and type of packages must be indicated (for example, "1 box" or "8 fiberboard drums") on a shipping paper (see§§ 172.202(a)(7) and 172.202(c)) either before or after the required basic description. The number and type of packaging, total quantity shipped, and destination marks are the only entries permitted to precede the basic description, and may be repeated after the basic description. As the shipping paper appears in your e-mail, we observe a few items that may be problematic. Although placed before the basic description, the word "BOX" appears to be under the column heading "Description," and is separated from the number of boxes, "1," which is placed under#

Page 2the column heading "PCS." Additionally, the placement of"PGII" appears to be placed after the weight ("26"). The packing group should be directly following the hazard class. We suggest either moving the word "BOX" to the first column (PCS) next to the "1" under a column heading such as "Number and Type of Packages," or moving column (PCS) so that it is above the word "BOX" and separated before or after the column heading "Description." Additionally, we suggest either moving "PGII" up to the line immediately following the hazard class ("8") or inserting vertical lines and horizontal lines where necessary; in effect creating columns and delineating more clearly the authorized split between the description requirements. I hope this information is helpful. Please contact this office should you have additional questions. Sincerely, T. Glenn Foster Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division#

Page 3Drakeford, Carolyn (PHMSA) From: Sent: To: Subject: INFOCNTR (PHMSA) l3 -ooJ../-(p Tuesday, February 19, 2013 2:20PM Drakeford, Carolyn (PHMSA) FW: Request for Interpretation- Description of Hazardous Material on Shipping Papers 172.202 Hi Carolyn, We received the following request for a formal letter of interpretation. Thanks, Victoria From: Richesin, Sandra --- Safety Compliance Specialist --- GO [mailto:sandra.richesin@fedex.com] Sent: Thursday, February 14, 2013 7:04PM To: INFOCNTR (PHMSA) Subject: Request for Interpretation- Description of Hazardous Material on Shipping Papers 172.202 February 14, 2013 Pipeline and Hazardous Materials Safety Administration (PHMSA) U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration East Building, 2nd Floor 1200 New Jersey Ave., SE Washington, DC 20590 We are requesting an interpretation concerning the placement of the type of package on the hazardous material shipping paper. Below is the format of the shipping paper: PCS HM DESCRIPTION WGT/Ibs 1 X BOX,UN2790,ACETIC ACID SOLUTION,8 26 PGII With the word "BOX" located in front of the hazardous material basic description which is the type of package required by 49 CFR 172.202(7), is this compliant with the requirements contained in 49 CFR 172.202 - Description of hazardous material on shipping papers? We appreciate your time in reviewing this request and look forward to receiving a response. Respectfully, Sandra Richesin Mike Brust 1#

Page 4Safety Compliance Specialist Manager- Corporate Safety FedEx Freight Inc. FedEx Freight Inc. 2200 Forward Drive 2200 Forward Drive PO Box 840 PO Box 840 Harrison, AR 72602-0840 Harrison, AR 72602-0840 870-704-5339 870-704-5346 2#

Page 5Reference No. 13-0046 From: Richesin, Sandra--- Safety Compliance Specialist--- GO [mc:JjJ1Q_~~cm_d.r9.J:i~_b§~lo.@~g-~):C_,_<;:Q!I!] Sent: Thursday, February 14, 2013 7:04 PM To: INFOCNTR (PHMSA) Subject: Request for Interpretation- Description of Hazardous Material on Shipping Papers 172.202 February 14, 2013 Pipeline and Hazardous Materials Safety Administration (PHMSA) U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration East Building, 2nd Floor 1200 New Jersey Ave., SE Washington, DC 20590 We are requesting an interpretation concerning the placement of the type of package on the hazardous material shipping paper. Below is the format of the shipping paper: PCS HM DESCRIPTION WGT/Ibs 1 X BOX,UN2790,ACETIC ACID SOLUTION,8 26 PGII With the word "BOX" located in front of the hazardous material basic description which is the type of package required by 49 CFR 172.202(7), is this compliant with the requirements contained in 49 CFR 172.202- Description of hazardous material on shipping papers? We appreciate your time in reviewing this request and look forward to receiving a response. Respectfully, Sandra Richesin Safety Compliance Specialist FedEx Freight Inc. 2200 Forward Drive PO Box 840 Harrison, AR 72602-0840 Mike Brust Manager - Corporate Safety FedEx Freight Inc. 2200 Forward Drive PO Box 840 Harrison, AR 72602-0840 870-704-5339 870-704-5346#