Con-way Freight — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Washington. DC 20590 1200 New Jersey Avenue SE Pipeline and Hazardous Administration Materials Safety JUN 1 1 2015 Ms. Marie Easley-Cook Hazardous Materials Administrator Con-way Freight 2211 Old Earhart Road, Suite 100 Ann Arbor, MI 48105 Reference No. 15-0087 Dear Ms. Easley Cook: This is in response to your letter dated April 27, 2015 regarding the shipper's certification prescribed in § 172.204 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171- 180). Specifically, you ask whether a shipper's certification may be signed using only the initials of the person certifying the shipment. In accordance with 49 CFR Part 172 Subpart C, each person who offers a hazardous material for transportation must certify that the material is offered for transportation by printing (manually or mechanically) on the shipping paper the certification contained in § 172.204(a)(1) or the certification (declaration) containing the language in § 172.204(a)(2). Further, in accordance with § 172.204(d), the certification must be legibly signed by a principal, officer, partner, or employee of the shipper or his agent; and may be signed manually, by typewriter, or by other mechanical means. The HMR do not define • the term signature; therefore, the signature requirement prescribed in § 172.204(d) may be satisfied by the use of initials provided the initials are traceable to the person certifying the hazardous materials for transportation. I trust this information is helpful. If you have further questions, please do not hesitate to contact this office. Sincerely, Bane 17A1 Duane Pfund International Standards Coordinator Standards and Rulemaking Division#

Page 2Wiener $172.204(d) Conway. FREIGHT Shpper's Signature 15-0087 April 27, 2015 U.S. DOT PHMSA Office of Hazardous Materials Standards Attn: PHH-10 East Building 1200 New Jersey Avenue, SE. Washington, DC 20590-0001 RE: Request for interpretation letter I am requesting formal clarification of the 172.204(d) signature requirement. My question is about the use of initials as a signature. The only letter of interpretation referencing a person's initials in connection with 172.204(d) is Reference No. 05-0005. It appears to be acceptable. Is it acceptable for a person certifying a hazardous material shipment to sign using their solely their initials? The question was posed to the Hazardous Material Information Center on today's date. The answer was initials could be used as the shipper's certification signature. Please confirm. Regards, Marie Easley-Cook Hazardous Materials Administrator Con-way Freight 2211 Old Earhart Road Suite 100 734-994-6600 Ann Arbor, MI 48105#