AECOM — 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 0 2015 Ms. Erin N. Jarman Environmental Scientist AECOM 1600 Perimeter Park Dr. Morrisville, NC 27560 Reference No. 15-0095 Dear Ms. Jarman: This is in response to your May 5, 2015 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to use of punctuation on a shipping paper. Specifically, you ask what types of punctuation may be used to separate the various components of the basic description on a shipping paper. A shipping description for a hazardous material should be entered on the shipping paper in accordance with the general entry provisions of § 172.201 and the basic description provisions of § 172.202. Section 172.201(a)(2) specifically requires that all shipping descriptions be legible and printed in English. Section 172.202(b) specifies that the basic description must also appear in sequence with no additional information interspersed. Punctuation used within the basic shipping description to separate the components of the description is not prohibited, but should not reduce legibility. Therefore, it is acceptable to use punctuation such as slashes, double slashes, spaces, commas, colons; semicolons, or columns to separate the different parts of the hazardous material basic description. I hope this satisfies your request. Sincerely, Annister T. Glenn Foster Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division#

Page 2Lehman §172.202(6) Shipping Papers AECOM 15-0095 May 5, 2015 Mr. Charles Betts, Director Office of Hazardous Material Standards Pipeline and Hazardous Materials Safety Administration U.S. Department of Transportation 1200 New Jersey Ave, SE East Building, 2ªd Floor Washington, DC 20590-0001 Dear Mr. Betts: I am writing to you for clarification concerning the appropriate punctuation to use when separating the various elements of the basic description on shipping papers. In 49 CFR 172.202(b), an example of the basic description provided shows the use of commas to separate the various elements of the basic description as follows: "UN2744, Cyclobutylchloroformate, 6.1, (8, 3), PGII" Is it permissible to use other types of punctuation in place of the commas? For example, would colons or semicolons be acceptable as long as the basic description contains all of the required elements and is in the proper sequence? If so, would the use of these alternate punctuation methods be permissible for all modes of transportation? Thank you in advance for your assistance in clarifying this question. Sincerely, Eir N. Jarman Erin N. Jarman Environmental Scientist ÀECOM AECOM 1600 Perimeter Park Drive Morrisville, NC 27560 Fax:919.461.1371 Tel: 919.461.1478 erin.jarman@aecom.com#

Page 3Dodd, Alice (PHMSA) From: Geller, Shelby CTR (PHMSA) Sent: To: Thursday, May 07, 2015 4:17 PM Subject: Hazmat Interps FW: Request for Formal Interpretation Attachments: Punctuation Permitted on Shipping Papers.pdf Dear Shante and Alice, Attached is a request for a formal letter of interpretation. Thanks, Shelby From: Jarman, Erin [mailto:erin.jarman@aecom.com] To: INFOCNTR (PHMSA) Sent: Thursday, May 07, 2015 2:48 PM Subject: Request for Formal Interpretation Dear Info Center, I have attached a request for formal interpretation related to punctuation used on shipping papers. If you have any questions, please feel free to contact me via e-mail or at the telephone number below. Have a great day! Erin N. Jarman Environmental Scientist, EHS Department D: 919-461-1478 F: 919-461-1371 erin.jarman@aecom.com AECOM 1600 Perimeter Park Dr. Suite 400 0: 919-461-1100 F: 919-461-1415 Morrisville, NC 27560 www.aecom.com This e-mail and any attachments contain AECOM confidential information that may be proprietary or privileged. If you receive this you should destroy the e-mail and any attachments or copie nessage in error or are not the intended recipient, you should not retain, distribute, disclose or use any of this information an#