{"operation":"document","citation":"25-0090","title":"Public Utilities Commission — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2026-03-12","effective_on":null,"summary":"25-0090 response to Public Utilities Commission concerning 172.202, 172.203.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-25-0090.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-25-0090.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-25-0090","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/2026-03/250090.pdf","body":"<<<PAGE 1>>>\n\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\nMarch 11, 2026\nMr. Tad Rumas\nPublic Utilities Commission\n180 E Broad Street\nColumbus, Ohio 43215\nReference No. 25-0090\nDear Mr. Rumas:\nThis letter is in response to your July 2, 2025 email requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) applicable to additional shipping paper\ndescription information for radioactive materials. It is your understanding that § 172.203(d)\nappears to indicate that all additional information (i.e., “entries”) must immediately follow the\nbasic description required by § 172.202. However, you note that § 172.203(d)(9)(ii) states that an\n“Exclusive Use Shipment” may be entered only once on the shipping paper in a clearly visible\nlocation” and § 172.203(d)(10) states that for the shipment of a package containing a highway\nroute controlled quantity of Class 7 (radioactive) materials the words “Highway route controlled\nquantity” or “HRCQ” must be entered in association with the basic description, while\n§§ 172.203(d)(1)–(d)(8) provide no such specificity.\nWe have paraphrased and answered your questions as follows:\nQ1. Does the phrase “[t]he description for a shipment of a Class 7 (radioactive) material must\ninclude the following additional entries” in § 172.203(d) indicate that the additional\ninformation (i.e., entries) must immediately follow the basic description (to include\nhorizontal or vertical format) only?\nA1. No. As stated in § 172.203(d), the phrase indicates that the information required by this\nparagraph, unless specifically instructed otherwise, is considered additional description\ninformation and must be a part of the hazardous material description for the radioactive\nmaterial, but not necessarily immediately before or after the basic description.\nQ2. Regarding the requirement for a highway route controlled quantity package in\n§ 172.203(d)(10), does the phrase “in association with” indicate that the additional\ninformation must immediately follow the basic description (to include horizontal or\nvertical format) only?\n\n<<<PAGE 2>>>\n\nA2. No. The phrase “in association with the basic description” means placing additional\ninformation as part of the basic description either immediately before, after, or\ninterspersed with the basic description. See, for example, the instructions for including a\ntechnical name in § 172.203(k) and the examples provided.\nQ3. Based on the answers to Q1 and Q2, would it be permissible for information required by\n§ 172.203(d)(1)–(d)(8) to be in another location on the shipping paper?\nA3. No. Section 172.203(d) specifies that the information must be included as part of the\nhazardous material description for the radioactive material.\nQ4. Regarding the requirement for a highway route controlled quantity package in\n§ 172.203(d)(10), and based on the answers to Q1 and Q2, when is information no\nlonger considered “in association with” the basic description?\nA4. See answer A2.\nQ5. Based on the answers to Q1 and Q2, when are entries considered “not included” with\nthe basic description?\nA5. Regarding the requirement in § 172.203(d) for the shipment description to include the\nfollowing additional entries, the term “entries” means information. As stated in answer\nA1, the additional information, as appropriate, must be included in the hazardous material\ndescription, not the basic description (as spelled out in § 172.202(b)).\nI hope this information is helpful. Please contact us if we can be of further assistance.\nSincerely,\nDirk Der Kinderen\nChief, Standards Development Branch\nStandards and Rulemaking Division\n\n<<<PAGE 3>>>\n\nCardez, E.\n25-0090\nFrom: INFOCNTR (PHMSA)\nTo: Baker, Yul (PHMSA)\nCc: Hazmat Interps\nSubject: FW: Written Interpretation Request\nDate: Wednesday, July 2, 2025 13:36:25\nAttachments: image001.png\nimage002.png\nGood afternoon,\nPlease see the following request for a letter of interpretation. Please let us know if you need\nanything else.\nBest,\nAminah\nFrom: tad.rumas@puco.ohio.gov <tad.rumas@puco.ohio.gov>\nSent: Wednesday, July 2, 2025 9:24 AM\nTo: PHMSA HM InfoCenter <PHMSAHMInfoCenter@dot.gov>\nSubject: Written Interpretation Request\nYou don't often get email from tad.rumas@puco.ohio.gov. Learn why this is important\nCAUTION: This email originated from outside of the Department of Transportation (DOT). Do\nnot click on links or open attachments unless you recognize the sender and know the content\nis safe.\nTo whom it may concern,\nI am seeking clarification on the proper and/or specific location for the additional description\nentries as required by 49CFR Part 172.203(d)(1) – (d)(10).\nSpecifically, 172.203(d) Radioactive material, provides the following: “the description for a\nshipment of a Class 7 (radioactive) material must include the following additional entries as\nappropriate” which appears to indicate that all additional entries must immediately follow the\nbasic description required by Part 172.202. However, 172.203(d)(9)(ii) provides “the statement\n‘Exclusive Use Shipment’ may be entered only once on the shipping paper in a clearly visible\nlocation” and 172.203(d)(10) provides “the words ‘Highway route-controlled quantity’ or\n‘HRCQ’ must be entered in association with the basic description”, while 172.203(d)(1) – (d)(8)\nprovides no such specificity.\nMy questions are as follows:\nQ1 – Does the term “the description for a shipment of a Class 7 (radioactive) material must\n\n<<<PAGE 4>>>\n\ninclude” indicate that the additional information must immediately follow the basic\ndescription (to include horizontal or vertical format) only?\nQ2 – Does the term “in association with” also indicate that the additional information must\nimmediately follow the basic description (to include horizontal or vertical format) only?\nQ3 – Based on the answer to Q1 & Q2, would it be permissible for information required by\n172.203(d)(1) – (d)(8) to be in another location on the shipping paper?\nQ4 – Based on the answer to Q1 & Q2, when are entries no longer considered “in association”\nwith the basic description?\nQ5 – Based on the answer to Q1 & Q2, when are entries no longer considered as “not\nincluded” with the basic description?\nFor reference, please see the example below.\nThank you in advance,\nTad Rumas\nDistrict Field Supervisor – Rad Coordinator\nTransportation Department\nMotor Carrier Enforcement Division\n180 E Broad Street\nColumbus, Ohio 43215\n\n<<<PAGE 5>>>\n\nCell: 614.205.6221\nTad.rumas@puco.ohio.gov","truncated":false,"body_characters":6541}