{"operation":"document","citation":"21-0024","title":"Matson Navigation Company — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2021-05-10","effective_on":null,"summary":"21-0024 response to Matson Navigation Company concerning 172.101.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-21-0024.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-21-0024.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-21-0024","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/hazmat/interpretations/75031/210024.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nMay 10, 2021\nJames Owen\nDangerous Goods Specialist\nSafety, Quality, Environment, and Security\nMatson Navigation Company\n426 N 44th St, Ste 250\nPhoenix, AZ 85008\nReference No. 21-0024\nDear Mr. Owen:\nThis letter is in response to your March 9, 2021, email requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) applicable to the use of italicized text and\nplural versus singular shipping names on shipping papers. Specifically, you ask:\nQ1. Section 172.101(c)(2) states that words in italics are not part of the proper shipping name,\nbut may be used in addition to the proper shipping name. You ask whether someone may\nuse only a portion of the italicized text.\nA1. In general, the answer is yes. However, use of only part of the italicized text is not\nadvised as it may misrepresent the hazard and cause frustration of your shipment. For\nexample, the Hazardous Materials Table (HMT; § 172.101) entry “UN2037, Receptacles,\nsmall, containing gas or gas cartridges (oxidizing), without release device, not refillable\nand not exceeding 1 L capacity” may not be represented on a shipping paper as\n“UN2037, Receptacles, small, containing gas (oxidizing), without release device, not\nrefillable and exceeding 1 L capacity.”\nQ2. You ask whether it is acceptable to enter a shipping description as singular when the\nHMT entry is plural. In your email, you provide the example of “fire extinguishers”\nentered as “fire extinguisher.”\n\n<<<PAGE 2>>>\n\nA2. The answer is yes. Section 172.101(c)(1) states that proper shipping names may be used\nin the singular or the plural and in either upper or lower case letters. Therefore, a shipper\nmay enter the proper shipping names on a shipping paper in the singular or plural form.\nFor example: “UN1044, Fire extinguishers” or “UN1044, Fire extinguisher” is\nacceptable.\nI hope this information is helpful. Please contact us if we can be of further assistance.\nSincerely,\nT. Glenn Foster\nChief, Regulatory Review and Reinvention Branch\nStandards and Rulemaking Division\n\n<<<PAGE 3>>>\n\nPOLLACK\n21-0024\nFrom: INFOCNTR (PHMSA)\nTo: Subject: Date: Dodd, Alice (PHMSA); Hazmat Interps\nFW: LOI - proper shipping names\nTuesday, March 9, 2021 12:44:30 PM\nHi Alice,\nPlease see the below interpretation request. Should you have any questions, please do not\nhesitate to reach out.\nRegards,\n-Breanna\n----------------------------------------------\nFrom: James Owen at PHX x5015 <JOwen@matson.com>\nSent: Wednesday, March 3, 2021 3:46:12 PM\nTo: PHMSA Website Manager <PHMSAWebsiteManager@dot.gov>\nSubject: LOI - proper shipping names\nCAUTION: This email originated from outside of the Department of Transportation (DOT). Do not click on links or\nopen attachments unless you recognize the sender and know the content is safe.\nGood afternoon,\nI am writing to request a letter of interpretation on two items that both relate to the proper shipping\nname on a shipping paper.\nMy first question is in regards to the entry in italics from the HMT. I understand that the italics\nportion is allowable but not mandatory. My question is, if someone uses only a portion of the italics\nis that still acceptable? An example is Aerosols. Would “Aerosols, flammable” be acceptable or since\na portion of the italics is being used (flammable), would the rest of the entry (each not exceeding 1 L\ncapacity) be required as well?\nThe second question is in relation to singular vs plural. I understand that if an entry is singular in the\nHMT it can also be plural when noted on the shipping papers. Is this true of the inverse? For example\ncan “Fire extinguishers” be declared as “Fire extinguisher”?\nJames Owen\nDangerous Goods Specialist\nSafety, Quality, Environment, and Security\nMatson Navigation Company\n426 N 44th St, Ste 250\nPhoenix, AZ 85008\nOffice 480-902-5015\nCell 480-653-1114\njowen@matson.com\n\n<<<PAGE 4>>>\n\nwww.matson.com\nNOTICE: This message, including any attachments, is intended for the use of the party to\nwhich it is addressed and may contain information that is privileged, confidential and exempt\nfrom disclosure. If you are not the intended recipient, any dissemination, distribution or\ncopying of this communication is strictly prohibited. If you have received this communication\nin error, please contact the sender immediately by reply e-mail, and delete the original and any\ncopies of this message. It is the sole responsibility of the recipient to ensure that this message\nand any attachments are virus free.","truncated":false,"body_characters":4610}