{"operation":"document","citation":"16-0104","title":"Ms. Amanda Hammon — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2016-08-22","effective_on":null,"summary":"16-0104 concerning 172.101, 172.202, 172.203, 172.301.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-16-0104.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-16-0104.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-16-0104","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2016/160104.pdf","body":"<<<PAGE 1>>>\n\nof Transportation\nU.S. Department\n1200 New Jersey Avenue, SE\nWashington, D.C. 20590\nPipeline and Hazardous\nMaterials Safety\nAdministration\nAUG 2 2 2016\nMs. Amanda Hammon\nProduct Safety Representative\n1144 East Newport Center Drive\nDeerfield Beach, FL 33442\nReference No. 16-0104\nDear Ms. Hammon:\nThis letter is in response to your June 9, 2016, email requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) applicable to voluntary information\ndescribing a hazardous material on shipping papers and package markings. We have\nparaphrased and answered your questions as follows:\nQ1.\nYou ask whether materials properly classified as identification number \"UN1133\" may\nbe described with both \"Adhesives\" and \"Adhesives, containing a flammable liquid\" as\nthe proper shipping name for the purposes of shipping papers and package markings.\nAl.\nThe answer is yes. In accordance with § 172.101(c)(2), \"Punctuation marks and words\nin italics are not part of the proper shipping name, but may be used in addition to the\nproper shipping name.\" For UN1133, the Hazardous Materials Table (HMT) lists the\nname \"Adhesives\" in Roman type as the proper shipping name. The phrase \"containing\nflammable liquid\" is in italics and, therefore, may be permissively included as part of the\nproper shipping name on shipping papers and package markings in accordance with part\n172 subparts C and D, respectively.\nQ2.\nYou ask whether a technical name may be provided on a shipping paper or package\nmarking in between the proper shipping name and hazard class for HMT entries that do\nnot include a \"G\" in Column 1.\nA2.\nThe answer is yes. Many entries in the HMT do not include a \"G\" in Column 1 and are\nnot otherwise required to include a technical name on a shipping paper under\n§ 172.203(k). However, a shipper may voluntarily include a technical name on a\nshipping paper following the basic description or in parenthesis between the proper\nshipping name and hazard class (see § 172.202(d)).\nSection 172.301(b) requires non-bulk packages containing a hazardous material, subject\nto the provisions of § 172.203(k), to be marked with the technical name. This section\nprohibits packages containing materials in Division 6.2 from displaying the technical\n\n<<<PAGE 2>>>\n\nname on the outside of the package. The HMR do not otherwise prohibit technical\nnames from being displayed on the outside of the package.\nQ3.\nYou ask whether the hazard class and packing group may be displayed on the outer\npackage following the identification number and proper shipping name in a location near\nthe hazard class label.\nA3.\nThe answer is yes. The HMR do not prohibit additional information from being\ndisplayed on the outer packaging after the information required by part 172 subpart D,\nprovided the information properly describes the material.\nI hope this information is helpful. Please contact us if we can be of further assistance.\nSincerely,\nserrasta\n-\nT. Glenn Foster\nChief, Regulatory Review and Reinvention Branch\nStandards and Rulemaking Division\n\n<<<PAGE 3>>>\n\nTehman\n172,200\nGoodall, Shante CTR (PHMSA)\nApplica belik\nFrom:\nRivera, Jordan CTR (PHMSA)\n110-0104\nSent:\nTuesday, June 14, 2016 10:10 AM\nTo:\nHazmat Interps\nSubject:\nFW: WRITTEN RESPONSE REQUIRED\nHi Shante/Alice,\nPlease submit this as a letter of interpretation. Please let me know if you have any questions.\nThanks,\nJordan\nFrom: Hammon, Amanda [mailto:AHammon@mapei.com]\nSent: Tuesday, June 14, 2016 7:41 AM\nTo: INFOCNTR (PHMSA)\nSubject: RE: WRITTEN RESPONSE REQUIRED\nJordan,\nThank you for submitting my formal request.\nAMANDA HAMMON\n1144 EAST NEWPORT CENTER DRIVE\nDEERFIELD BEACH, FLORIDA 33442\nRegards,\nAmanda Hammon\nFrom: INFOCNTR (PHMSA) [mailto: INFOCNTR.INFOCNTR@dot.gov]\nTo: Hammon, Amanda\nSent: Monday, June 13, 2016 4:46 PM\nSubject: RE: WRITTEN RESPONSE REQUIRED\nDear Amanda,\nWe have received your request for a written letter of interpretation regarding the hazardous materials regulations (49\nCFR Parts 171-180). The hazardous materials regulations are available at the following URL:\nhttp://phmsa.dot.gov/regulations\nIn order for your request to be submitted, you must respond to this email with a mailing address.\nTypically, written letters of interpretation are responded to at minimum of approximately 8 weeks from when they are\nreceived by the Office of Hazardous Materials Standards. However, delivery time of a written interpretation can vary\nmarkedly based on topic complexity and the backlog of letters to be completed.\n1\n\n<<<PAGE 4>>>\n\nSincerely,\nJordan, Hazardous Materials Specialist\nAn e-mail response from this office is considered informal guidance. Formal guidance may be requested in accordance\nwith 49 CFR 105.20. http://phmsa.dot.gov/hazmat/regs/interps\nFrom: Hammon, Amanda [mailto:AHammon@mapei.com]\nTo: PHMSA HM InfoCenter\nSent: Monday, June 13, 2016 2:01 PM\nSubject: WRITTEN RESPONSE REQUIRED\nI greatly appreciate the help and phone calls regarding my questions below, however I need an answer in writing.\nThanks,\nAmanda Hammon\nFrom: Hammon, Amanda\nTo: 'phmsa.hm-infocenter@dot.gov'\nSent: Thursday, June 09, 2016 9:28 AM\nSubject: Additonal Information On HazMat Packaging\nTo Whom It May Concern,\nFirst off, what are the acceptable proper shipping name(s) for UN1133; Adhesives containing a flammable liquid. Is\nUN1133; Adhesives, UN1133; Adhesives containing a flammable liquid, or both correct proper shipping names? This\nproper shipping name will be included on the shipping papers as well as on the outer packaging, next to the hazard class\nlabel.\nSecondly, is it prohibited to include technical names in between the proper shipping name and the hazard class for\nhazardous material descriptions and proper shipping names that do not contain a G in column 1 of 172.101 Hazardous\nMaterials Table? These technical names would accurately describe the substances triggering the classification and would\nbe included on the shipping papers as well as on the outer packaging, next to the hazard class label.\nFinally, is it prohibited to include the hazard class and packing group on the outer packaging where it would follow the\nUN number and proper shipping name, and also be located next to the hazard class label?\nI would greatly appreciate the response to the questions above be communicated via email so that I may report back to\nupper management and document appropriately. Thank you so much.\nRegards,\nAmanda Hammon\nAmanda Hammon - Product Safety Representative | Research & Development\nT. 954-246-8542 | M. 954-478-5215\nemail ahammon@mapei.com\nNOTICE: This communication, including any attachment, contains information that is confidential and that may also be legally privileged, and is intended only for the exclusive use of the\nndividual named as the recipient. If the reader of this message is not the intended recipient, you have received this transmission in error and any review, dissemination, distribution o\nmail and destroy all copies of the original message or contact me by phone. Thank you.\nopying of this communication or any attachment to this transmission is strictly prohibited. If you have received this transmission in error, please immediately notify the sender by reply e\n2","truncated":false,"body_characters":7204}