Nutrien — Hazardous Materials Safety Interpretation

Page 10 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, DC 20590 NOV O € 2018 Clayton Droste Nutrien 3005 Rocky Mountain A venue Loveland, CO 80534 Reference No. 18-0068 Dear Mr. Droste: This letter is in response to your May 9, 2018, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 1 71-180) applicable to the requirements for describing a hazardous material on a shipping paper. Specifically, you ask if"CA" is an acceptable abbreviation for the word "case" when describing the type of packaging on a shipping paper. The answer is no. Section 172.202(a)(7) allows for the use of abbreviations to indicate the type of packaging on a shipping paper provided that the abbreviations are commonly accepted and recognizable. It is the opinion of this Office that "CA" is not a commonly recognizable abbreviation for the word "case." I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, ITkD~ Chief, Standards Development Branch Standards and Rulemaking Division#

Page 2!anuary, Ikeya CTR (PHMSA) From: Sent: To: Subject: INFOCNTR (PHMSA) Wednesday, May 09, 2018 5:22 PM Hazmat Interps FW: Interpretation question Hi lkeya & Alice, Below is a request for a letter of interpretation. Mr. Droste spoke with Breanna about his question. Please let me know if you have any questions. Thanks, Jodi From: Clay Droste (mai1to:Clay.Droste@nutrien.com1 Sent: Wednesday, May 9, 2018 11:34 AM To: Gale, John (PHMSA) <john.gale@dot.gov> Subject: Interpretation question John, I got your email address from the PHMSA website and would like some clarification. Nowhere in the regulation does it give proper abbreviations for packages but allows for abbreviations in 172.202(a)(7). We have been audited by several Federal auditors and never had an issue with our shipping papers. I'm now having an issue with the use of CA as an abbreviation for the word Case. For example, lCA, for 1 Case. Again, this has never been an issue. Would you be so kind to share your opinion with me on this matter? I appreciate your time and expertise in this matter. Thanks, Clayton Droste Advisor, Commercial Vehicle Compliance Product Stewardship & Regulatory Affairs 3005 Rocky Mountain Ave Loveland, CO 80534 t 970-685-3857 C 970-397-7016 clay.droste@nutrien.com www.nutrien.com i~lutrien- 1.•: ,, .. ,;.· ', ! 1:11,,!-i·r, , 1\Jui11i•r:'·_. ,-·,n- ,: ~--c-i 1./ ,,1 w;•:i!y,,_::h,. ,. 1 1ct'- i;, ' .. ·: https://www.nutrien.com/important- notice https://www.nutrien.com/avis-important#