{"operation":"document","citation":"25-0103","title":"Lennox Corporate — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2025-09-30","effective_on":null,"summary":"25-0103 response to Lennox Corporate concerning 172.201.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-25-0103.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-25-0103.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-25-0103","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/2025-09/250103.pdf","body":"<<<PAGE 1>>>\n\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\nSeptember 30, 2025\nMr. Robert (Bob) Johnson\nLennox Corporate\n2140 Lake Park Blvd.\nRichardson, TX 75080\nReference No. 25-0103\nDear Mr. Johnson:\nThis letter is in response to your July 23, 2025 letter requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) applicable to the preparation of shipping\npapers. You provide a sample shipping paper and note that you were previously issued guidance\nthat the sample provided meets the requirements in § 172.201(a)(1)(i). Furthermore, you note\nthat a carrier recently expressed concern with use of the term “Dangerous Goods” as a header for\neach hazardous material description as shown in the sample shipping paper. You ask whether the\nsample provided complies with the shipping paper requirements in § 172.201(a).\nYes. Display of the term “Dangerous Goods” in the manner shown does not conflict the\nrequirements for the description of hazardous materials on a shipping paper. Moreover, when\ndescribing hazardous materials that are included on a shipping paper, a person is required to use\none of the methods listed in § 172.201(a)(1)(i) through (a)(1)(iii), as the word “or” (emphasis\nadded) is used to indicate three separate options to identify hazardous materials on a shipping\npaper. Listing the hazardous materials first as shown in the sample shipping paper provided in\nyour incoming letter meets the requirements in § 172.201(a)(1)(i).\nI hope this information is helpful. Please contact us if we can be of further assistance.\nSincerely,\nDirk DerKinderen\nChief, Standards Development Branch\nStandards and Rulemaking Division\n\n<<<PAGE 2>>>\n\nCardez, E.\n25-0103\nFrom: INFOCNTR (PHMSA)\nTo: Baker, Yul (PHMSA)\nCc: Hazmat Interps\nSubject: FW: Interpretation Request Related to 49 CFR 172.201(a)(1)\nDate: Wednesday, July 23, 2025 16:36:06\nAttachments: image003.png\nHi Yul,\nPlease see the below interpretation request.\nLet us know if you need anything,\n-Breanna\nFrom: Johnson, Robert <Robert.Johnson@Lennox.com>\nSent: Wednesday, July 23, 2025 7:08 AM\nTo: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov>\nSubject: Interpretation Request Related to 49 CFR 172.201(a)(1)\nYou don't often get email from robert.johnson@lennox.com. 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 is\nsafe.\nTo whom it may concern,\nI would like to request a formal interpretation regarding whether the following format for listing\nHAZMAT on a shipping paper satisfies the requirements of 172.201(a)(1)(i) & (ii):\n\n<<<PAGE 3>>>\n\nConsignee:\nShipper:\nNo.\nUnits\nShp\nType\nPkg.\nQty\nSKU\nspecial marks and Exceptions\nDescriptions of articles\nWeight\n(in 1bs)\nor rate\nClass\n1\nUN2857, Refrigerating machines\n**** DANGEROUS GOODS******\n(1,077.3 kg)\n2,375 | FAK 77.5\ngases),\n(containing non-flammable, non-toxic\n2.2\n1\nON2857, Refrigerating machines\n*** DANGEROUS GOODS\n12,154.6 kg) |\n4,750\nPAK 77.5\n(gases), 2.2\n| (containing non-flammable, non-toxic\n3\n| AIR CONDITIONERS, FURNACES,\nCOOLING EQUIPMENT, AND MATERIALS BQUIPMENT, AND\nSOLAR HEATING AND\n3 | PAK 27.5\nDISTRIBUTION THERBOF.\n| SUPPLIES USED IN THE MANUFACTURE, SALE, AND\nTotals\n9,503 |\nThe HAZMAT Hotline was contacted in 2007 to check if this format met the intent of (a)(i) and (a)\n(ii). Based on the positive verbal response received back in 2007 this format was implemented\nand used for the past 18 years with zero objections. We recently had one carrier object to the\nheader ****** DANGEROUS GOODS ****** which is why I am requesting a formal\ninterpretation.\nAs supplemental information:\n(a) the HAZMAT/DG line items are always listed first,\n(b) use of the term Dangerous Goods in the header is due to a large number of international\nshipments, and\n(c) the weight in kg was in response to a specific request from Transport Canada over a decade\nago\nThank you,\nRobert (Bob) Johnson\nManager, EHS\nLennox Corporate\n2140 Lake Park Blvd. Richardson, TX 75080\n(0) +1 972-497-7532 (c) +1 972-569-7114\nwww.lennox.com\nILLENNOX\n\n<<<PAGE 4>>>\n\n§ 172.201 Preparation and retention of shipping papers.\ndescription must conform to the following requirements:\nContents. When a description of hazardous material is required to be included on a shipping paper, that\n(1) When a hazardous material and a material not subject to the requirements of this subchapter are\ndescribed on the same shipping paper, the hazardous material description entries required by S\n172.202 and those additional entries that may be required by § 172.203:\nMust be entered first, or\n(ii)\nmaterial not subject to the requirements of this subchapter, except that a description on a\nMust be entered in a color that clearly contrasts with any description on the shipping paper of a\nreproduction of a shipping paper may be highlighted, rather than printed, in a contrasting color (the\nand (4)), or\nprovisions of this paragraph apply only to the basic description required by § 172.202(a)(1), (2), (3),\nMust be identified by the entry of an \"X\" placed before the basic shipping description required by S\n172.202 in a column captioned \"HM.\" (The \"X\" may be replaced by \"RQ.\" if appropriate.)\n(2)\ntransportation purposes must be legible and printed (manually or mechanically) in English.\nThe required shipping description on a shipping paper and all copies of the shipping paper used for\n(3) Unless it is specifically authorized or required in this subchapter, the required shipping description may\nnot contain any code or abbreviation.\n(4) A shipping paper may contain additional information concerning the material provided the information\nadditional information must be placed after the basic description required by & 172.202(a)\ns not inconsistent with the required description. Unless otherwise permitted or required by this subpart","truncated":false,"body_characters":5996}