Lennox Corporate — Hazardous Materials Safety Interpretation

Page 11200 New Jersey Avenue, SE Washington, DC 20590 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration September 30, 2025 Mr. Robert (Bob) Johnson Lennox Corporate 2140 Lake Park Blvd. Richardson, TX 75080 Reference No. 25-0103 Dear Mr. Johnson: This letter is in response to your July 23, 2025 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the preparation of shipping papers. You provide a sample shipping paper and note that you were previously issued guidance that the sample provided meets the requirements in § 172.201(a)(1)(i). Furthermore, you note that a carrier recently expressed concern with use of the term “Dangerous Goods” as a header for each hazardous material description as shown in the sample shipping paper. You ask whether the sample provided complies with the shipping paper requirements in § 172.201(a). Yes. Display of the term “Dangerous Goods” in the manner shown does not conflict the requirements for the description of hazardous materials on a shipping paper. Moreover, when describing hazardous materials that are included on a shipping paper, a person is required to use one of the methods listed in § 172.201(a)(1)(i) through (a)(1)(iii), as the word “or” (emphasis added) is used to indicate three separate options to identify hazardous materials on a shipping paper. Listing the hazardous materials first as shown in the sample shipping paper provided in your incoming letter meets the requirements in § 172.201(a)(1)(i). I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, Dirk DerKinderen Chief, Standards Development Branch Standards and Rulemaking Division#

Page 2Cardez, E. 25-0103 From: INFOCNTR (PHMSA) To: Baker, Yul (PHMSA) Cc: Hazmat Interps Subject: FW: Interpretation Request Related to 49 CFR 172.201(a)(1) Date: Wednesday, July 23, 2025 16:36:06 Attachments: image003.png Hi Yul, Please see the below interpretation request. Let us know if you need anything, -Breanna From: Johnson, Robert <Robert.Johnson@Lennox.com> Sent: Wednesday, July 23, 2025 7:08 AM To: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov> Subject: Interpretation Request Related to 49 CFR 172.201(a)(1) You don't often get email from robert.johnson@lennox.com. Learn why this is important 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. To whom it may concern, I would like to request a formal interpretation regarding whether the following format for listing HAZMAT on a shipping paper satisfies the requirements of 172.201(a)(1)(i) & (ii):#

Page 3Consignee: Shipper: No. Units Shp Type Pkg. Qty SKU special marks and Exceptions Descriptions of articles Weight (in 1bs) or rate Class 1 UN2857, Refrigerating machines **** DANGEROUS GOODS****** (1,077.3 kg) 2,375 | FAK 77.5 gases), (containing non-flammable, non-toxic 2.2 1 ON2857, Refrigerating machines *** DANGEROUS GOODS 12,154.6 kg) | 4,750 PAK 77.5 (gases), 2.2 | (containing non-flammable, non-toxic 3 | AIR CONDITIONERS, FURNACES, COOLING EQUIPMENT, AND MATERIALS BQUIPMENT, AND SOLAR HEATING AND 3 | PAK 27.5 DISTRIBUTION THERBOF. | SUPPLIES USED IN THE MANUFACTURE, SALE, AND Totals 9,503 | The HAZMAT Hotline was contacted in 2007 to check if this format met the intent of (a)(i) and (a) (ii). Based on the positive verbal response received back in 2007 this format was implemented and used for the past 18 years with zero objections. We recently had one carrier object to the header ****** DANGEROUS GOODS ****** which is why I am requesting a formal interpretation. As supplemental information: (a) the HAZMAT/DG line items are always listed first, (b) use of the term Dangerous Goods in the header is due to a large number of international shipments, and (c) the weight in kg was in response to a specific request from Transport Canada over a decade ago Thank you, Robert (Bob) Johnson Manager, EHS Lennox Corporate 2140 Lake Park Blvd. Richardson, TX 75080 (0) +1 972-497-7532 (c) +1 972-569-7114 www.lennox.com ILLENNOX#

Page 4§ 172.201 Preparation and retention of shipping papers. description must conform to the following requirements: Contents. When a description of hazardous material is required to be included on a shipping paper, that (1) When a hazardous material and a material not subject to the requirements of this subchapter are described on the same shipping paper, the hazardous material description entries required by S 172.202 and those additional entries that may be required by § 172.203: Must be entered first, or (ii) material not subject to the requirements of this subchapter, except that a description on a Must be entered in a color that clearly contrasts with any description on the shipping paper of a reproduction of a shipping paper may be highlighted, rather than printed, in a contrasting color (the and (4)), or provisions of this paragraph apply only to the basic description required by § 172.202(a)(1), (2), (3), Must be identified by the entry of an "X" placed before the basic shipping description required by S 172.202 in a column captioned "HM." (The "X" may be replaced by "RQ." if appropriate.) (2) transportation purposes must be legible and printed (manually or mechanically) in English. The required shipping description on a shipping paper and all copies of the shipping paper used for (3) Unless it is specifically authorized or required in this subchapter, the required shipping description may not contain any code or abbreviation. (4) A shipping paper may contain additional information concerning the material provided the information additional information must be placed after the basic description required by & 172.202(a) s not inconsistent with the required description. Unless otherwise permitted or required by this subpart#