Matson Navigation Company — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, DC 20590 May 10, 2021 James Owen Dangerous Goods Specialist Safety, Quality, Environment, and Security Matson Navigation Company 426 N 44th St, Ste 250 Phoenix, AZ 85008 Reference No. 21-0024 Dear Mr. Owen: This letter is in response to your March 9, 2021, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the use of italicized text and plural versus singular shipping names on shipping papers. Specifically, you ask: Q1. Section 172.101(c)(2) states that words in italics are not part of the proper shipping name, but may be used in addition to the proper shipping name. You ask whether someone may use only a portion of the italicized text. A1. In general, the answer is yes. However, use of only part of the italicized text is not advised as it may misrepresent the hazard and cause frustration of your shipment. For example, the Hazardous Materials Table (HMT; § 172.101) entry “UN2037, Receptacles, small, containing gas or gas cartridges (oxidizing), without release device, not refillable and not exceeding 1 L capacity” may not be represented on a shipping paper as “UN2037, Receptacles, small, containing gas (oxidizing), without release device, not refillable and exceeding 1 L capacity.” Q2. You ask whether it is acceptable to enter a shipping description as singular when the HMT entry is plural. In your email, you provide the example of “fire extinguishers” entered as “fire extinguisher.”#

Page 2A2. The answer is yes. Section 172.101(c)(1) states that proper shipping names may be used in the singular or the plural and in either upper or lower case letters. Therefore, a shipper may enter the proper shipping names on a shipping paper in the singular or plural form. For example: “UN1044, Fire extinguishers” or “UN1044, Fire extinguisher” is acceptable. I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, T. Glenn Foster Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division#

Page 3POLLACK 21-0024 From: INFOCNTR (PHMSA) To: Subject: Date: Dodd, Alice (PHMSA); Hazmat Interps FW: LOI - proper shipping names Tuesday, March 9, 2021 12:44:30 PM Hi Alice, Please see the below interpretation request. Should you have any questions, please do not hesitate to reach out. Regards, -Breanna ---------------------------------------------- From: James Owen at PHX x5015 <JOwen@matson.com> Sent: Wednesday, March 3, 2021 3:46:12 PM To: PHMSA Website Manager <PHMSAWebsiteManager@dot.gov> Subject: LOI - proper shipping names CAUTION: This email originated from outside of the Department of Transportation (DOT). Do not click on links or open attachments unless you recognize the sender and know the content is safe. Good afternoon, I am writing to request a letter of interpretation on two items that both relate to the proper shipping name on a shipping paper. My first question is in regards to the entry in italics from the HMT. I understand that the italics portion is allowable but not mandatory. My question is, if someone uses only a portion of the italics is that still acceptable? An example is Aerosols. Would “Aerosols, flammable” be acceptable or since a portion of the italics is being used (flammable), would the rest of the entry (each not exceeding 1 L capacity) be required as well? The second question is in relation to singular vs plural. I understand that if an entry is singular in the HMT it can also be plural when noted on the shipping papers. Is this true of the inverse? For example can “Fire extinguishers” be declared as “Fire extinguisher”? James Owen Dangerous Goods Specialist Safety, Quality, Environment, and Security Matson Navigation Company 426 N 44th St, Ste 250 Phoenix, AZ 85008 Office 480-902-5015 Cell 480-653-1114 jowen@matson.com#

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