{"operation":"document","citation":"98-0224","title":"H.B. Fuller Automotive Company — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1998-08-14","effective_on":null,"summary":"98-0224 response to H.B. Fuller Automotive Company concerning 172.202.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-98-0224.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-98-0224.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-98-0224","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/1998/980224.pdf","body":"<<<PAGE 1>>>\n\n-1\nU.S.Department\nof Transportation\n400 Seventh Street, S.W\nWashington, DC. 20590\nSpecial Programs\nResearch and\nAdministration\nAUG 1 4 1998\n•\nMr. Eugene J. Secor\nEHS/Transportation Specialist\nRef. No.\n98-0224\nH.B. Fuller Automotive Company\n31601 Research Park Drive\nMadison Heights, Michigan 48071\nDear Mr. Secor:\nThis responds to your letter concerning shipping paper\nrequirements of the Hazardous Materials Regulations (HMR; 49 CFR\nParts 171-180). Specifically, you ask whether information\nconcerning a shipment may be included on a shipping paper so that\nit can serve the dual purposes of a bill of lading and a packing\nThe HMR do not specify a particular format for shipping papers. .-\nRather, Subpart C of Part 172 sets forth the information that\nmust be included on shipping papers and the order in which that\ninformation must appear.\nyou enclosed with your\nThe \"mock-up\" shipping document that\nprovided the requirements of Subpart C are met.\nletter may be used as a shipping paper\nIn this regard,\nwe note that your \"mock-up\" does not include\nhazardous materials shipping descriptions. For shipments of\nhazardous materials, the required shipping description means the\nbasic description required by § 172.202, and additional\ndescription information required by § 172.203. The basic\ndescription, consisting of the proper shipping name for the\nmaterial as identified in § 172.101 of the Hazardous Material\nTable, the hazard class, the identification number and the\npacking group, if any, must be shown in sequence with no\nadditional information interspersed. Additional information,\nas that required by § 172.203; or other additional\ninformation concerning the hazardous material must be placed\nafter the basic description on a shipping paper, except that\ntechnical name or chemical group name for a generic description\nmay follow the proper shipping name.\nallowed to be placed before the basic description is quantity\nThe only information\nshipped, and the type of packaging and destination marks (see\n§ 172.201 (a) (2) (iii), § 172.201 (a) (4) and § 172.202 (c)). Thus,\nyou may include packing slip data applicable to a hazardous\nmaterials shipment on a shipping paper, but that information must\n172.202\n\n<<<PAGE 2>>>\n\n•\n2\nbe shown after the required shipping description.\nAs you develop your shipping documents, you should also be aware\nshipping paper (see\nOI requirements for including a shipper's certification on the\nnazardous materials must be accompanied by emergency response\n§ 172.204). In addition, most shipments of\ninformation,\nincluding an emergency response telephone number\n(see Subpart G of Part 172).\nI hope this information is helpful. If you have further\nquestions, please do not hesitate to contact this office.\nSincerely,\nThoman A. Allan\nThomas G. Allan\nSenior Transportation Regulations Specialist\nvIlice oI Hazardous Materials Standards\n•\n•........... *\n...........\n\n<<<PAGE 3>>>\n\nH.B. Fuller Automotive Company\nGorsky\n31601 Research Park Drive\n§172.202\n(810) 585-2200 • (800) 633-7789\nMadison Heights, Michigan 48071\nAUGUST 5, 1998\nFAX (810) 585-3699\nUS DEPARTMENT OF TRANSPORTATION\nRESEARCH AND SPECIAL PROGRAMS ADMINISTRATION\nSTANDARDS DEVELOPMENT, DHM-11\n400 SEVENTH STREET, S.W.\nWASHINGTON, DC 20590\nATTENTION: MR DELMER F. BILLINGS\nCHIEF, REGULATIONS DEVELOPMENT\nDear Mr. Billings:\nIn an effort to streamline and consolidate our paper flow, the question has arisen as to what exactly can be\nof papers generally accompany a shipment regardless of whether the material is hazardous or not. These\nput on a shipping paper (Bill of Lading). The impetus behind this effort has to with the fact that two sets\npapers are the Bill of Lading which goes with the truck driver and a packing list which is usually attached\nto the container for a specific customer.\nlegally as a shipping paper and as a packing list while also being mindful of 172.201(4). Would inclusion\nThe crux of the question is whether a shipping paper can serve theses duel purposes; namely, function\nof normal packing slip data on the BL after all shipping entries have been entered be a violation? I have\nattached a \"mock up\" of what we propose to do. Assuming our proposal is in compliance, could you\ncomment on a better lay out for the mock-up?\nRest assured that we are not doing this currently; this is simply a query at this point. If there are any\nquestions, feel free to contact me at 810-498-1317.\nSincerely,\nHB FULLER COMPANY\nEsperar\nEUGENE J SECOR\nEHS/TRANSPORTATION SPECIALIST\ncc: Sarah Obser -- Willow Lake B\nBrian Lim - Lexington Ave\nCathy Boussie - Madison Heights\n\n<<<PAGE 4>>>\n\n→ so in\n|BILL OF LADING NO.\n44831\nDATE\nPACE\n6/1/98\n1 of 2\n02000298\nI SHP FROM\nSHIP TO DEST\nGENERAL MOTORS OF CANADA\nPLANT *2 DOCK QQQ\nGENERAL MOTORS OSHAWA\nCANADA\nOSHAWA, ONTARIO L1H 8P7\nPREMHIM TRANSPORTATION AUTHORIZATION\nFOB Terms: FOB Shipping Point/Collect\nMODE\nMETHOD\nSCAC\nREGULATORY INFORMATION ONLY - RECEIVING INFORMATION BELOW\nNUMBER KIND\nPACKAGING\nH.M.\nSPECIFIC MARKS AND EXCEPTIONS\nDESCRIPTION OF ARTICLES\nSubject to Correction\nWEIGHT\n-\n9\nBX\nNOT A REGULATED MATERIAL,\nLIQUID OR PASTE, IN BARRELS, BOXES OR PACKAGE\nCOMPOUNDS VEHICLE BODY SEALER OR SOUND DEADENER,\n153\n1235, ITEM # 50315, CLASS 55\nFS703M30 HOT MELT STICK\n1004269007\n3\nMD\n-\nCOMPOUNDS VEHICLE BODY SEALER OR SOUND DEADENER,\nNOT A REGULATED MATERIAL,\n15150\n1235, ITEM # 50315, CLASS 55\nLIQUID OR PASTE, IN BARRELS, BOXES OR PACKAGE\nWC2231 MP UNDERBODY COATING\n1100010202\nGROSS WEIGHT\nNET WEIGHT\n15903\nRECEIVING INFORMATION BELOW\nCUST. RELEASE\nCUST. PURCHASE ORDER CUST. PART NO./\nRESOURCE DESCRIPTION\nCUST. SEAL NO\nRESOURCE NO.\nEFTEC ORDER NO.\nCONTAINER UOM\nQUANTITY\nCUSTOMER\nUOM LOT NUMBER\n•\n81HM6\nOSR842443\n2027505\n52799\nFS703M30 HOT MELT STICK\n1004269007\nBX\"\n450\n1480556431\n1480556444\n**CONTINUED**\n\n<<<PAGE 5>>>\n\no i.\nI BAL OF 408310.\nDATE\n6/1/98\nPAGE\n2 of 2\n02000298\nI SHIP FROM\nSHIP TO DEST\nGENERAL MOTORS OSHAWA\nGENERAL MOTORS OF CANADA\nSHAWA, ONTARIO LTH 8P\nLANT #2 DOCK QQC\nPREMIUM TRANSPORTATION AUTHORIZATON\nFOB Terms: FOB Shipping Point/Collect\nMODE\nMETHOD\nSCAC\nRECEIVING INFORMATION BELOW\nCUST. PURCHASE ORDER/ CUST. PART NO. /\nCUST. RELEASE\nRESOURCE DESCRIPTION\nCUST. SEAL NO.\nRESOURCE NO.\nEFTEC ORDER NO.\nCONTAINER UOM\nQUANTITY\nCUSTOMER\nƯOM\nLOT NUMBER\nOSR842442\nDHB01217\nSEAL-0270\n9984175\n52800\nWC2231MP UNDERBODY COATING\n1100010202\nMD\n15000\nLB\n10000\n3000\n2000\n1480554000\n1480553996\n1480553213\n*HASN REQUIRED: SHIP TIME\nMessages: Ship on Tuesday - Receiving hours at GM are\n(8:30 - 12:00 noon) only.\nBar code must have viscosity.\nMessages: VIS & BKFLD REQUIRED ON LABEL - CERTS REQ'D.\n90 DAY EXPIRATION\nGREEN DRUM W/LINER & COVER SHEET\n\n<<<PAGE 6>>>\n\n-CARRIER\nSTRAIGHT BILL OF LADING - SHORT FORM\nORIGINAL. - NOT NEGOTIABLE\nBILL OF LADING NO.\n*ETEC North America, L.L.C.\nAT\nRECEIVED sulet the hasicans and and id ant to the dare teste the il of LadiSHMENT ID\nCOLLECTED ON DELIVERY\nEQUIPMENT ID\nAMT $.\nMODE\nMETHOD\nSCAG\nFEE $.\nTOTAL $.\nNUMBER KIND\nPACKAGING\nH.M.\nSPECIFIC MARKS AND EXCEPTIONS\nDESCRIPTION OF ARTICLES\nSubject to Correction\nWEIGHT\ncondition of applicable bill\nSubject to Section 7 of\nof lading. If this shipment is\nsignee without recourse on\nto delivered to the con\nor shall sign the following\nthe consignor, the consign-\nstatement.\nBL format ve\ndelivery of this shipment\nThe carrier shall not make\nwithout payment of freight\nand all other lawful charges.\nAurally ase!!\nEFTEC North America, L.L.C.\n(Signature of Consignor)\n\"To be Prepaid.\"\naid, write or stamp her\ncharges are to bo pr\nReceived $\nthe charges on the property\nto apply in prepayment of\ndescribed hereon.\nAgent or Cashier\nacknowledges only the\n(The signalure here\namount prepaid.)\nCharges Advanced\nFOR\nCHEMICAL\nEMERGENCY\n*If the shipment moves between two ports by a carner by water, the law requires that the bill of lading\nCALL\nNOTE - Where the ratc is dependent on valuc, shippers are required to state specifically in wnting the\nshall state whether it is carrier's or shipper's weisht.\nSTATED\nSHIPPER\nCHEMTREC\nagreed or declared value of the property.\nBE NOT EXCEEDING 165 CENTS PER POUND FOR EACH\nISTRIBUTION PACKAGE\n1-800-424-9300\nDAY OR NIGHT\nIN PROPER CONDITION FOR TRANSPORTATION, ACCORDING TO THE APPLICABLE REGULATIONS OF THE DEPARTMENT OF TRANSPORTATION.\nTHIS IS TO CERTIFY THAT THE ABOVE NAMED MATERIALS ARE PROPERLY CLASSIFIED, DESCRIBED, PACKAGED, MARKED AND LABELED AND ARE\nDox mares ceriseat there, and alone reco openis i to consider\nreight Classification.\nrate more oms enamp, not a part of bill of lading approved by the\nPermanent post oflice address of shipper\nEFTEC North America, L.L.C\n(Shipper)\nPer\nORIGINAL - NOT NEGOTIABLE\nAgent, Per.\n\n<<<PAGE 7>>>\n\nEMERGENCY RESPONSE GUIDES (ERG)\nPOTENTIAL HAZARDS\nERG 11\nFIRE OR EXPLOSION - Flammable/combüstible material; may be ignited by heat, sparks or flames. May inte other combustible matertals (wood; paper, öll, etc.) Container may explode in heat of fire. Reaction with fuels may be violent. Runoff\nto sewer may create fire or explosion hazard.\nHEALTH HAZARDS - Maybe fatal if inhaled, swallowed or absorbed through ski Contact may cause burns io skim and ayes, fire may produca ritaling or poisonous gases. Rumit tom, tre control or diligion water may cause pollution\".\nKeep unnecessary people away; isolate hazard area and deny entry. Stay upwind; keep out of low areas. Posive pressure self-contained breathing apparatus (SCA) and strictural firefighters protective clothing will provide limited protection.\nEMERGENCY ACTION\nCALL Emergency Response Telephone Number on Shipping Papers first. If Shipping Paper not avallable or no answer, CALL CHEMTREG AT 1-800-424-9300. If water pollution occurs, notify the appropriate authorities.\nMove container from fire area If you can do it without risk. Apply cooling water to sides of containers that are exposed to flames until well after. fire is out. Stay away from ends of tanks. For massive fire in cargo area, use Unmanned hose holde\nEIRE - Small Fires: Dry chemical, CO2, water spray or regular foam. Large Fires: Water spray, fog br regular foam\nSPILL OR LEAK - Shut off Ignition sources; no flares, smoking or flames in hazard area. Keep combustibles. (wood. paper, oil, etc.) away from spilled material. Do not touch or walk through spilled material. Small Spills: Take up with sand or\nor monitor nozzles; if this is impossible, withdraw from area and let fire burn.\nFIRST AID - Move-victim to fresh air and call emergency medical care; if not breathing, give artificial respiration; if breathing is difficult, give oxygen. In case of contact with material, immediately flush skin or eyes with running water for at least.\nother noncombustible absorbent material and place into containers for later disposal: Large Spills: Dike far ahead of liquid spill for later disposal..\n15 minutes: Remove and isolate contaminated clothing and shoes at the site. Keep victim quiet and maintain normal body temperature.\nPOTENTIAL HAZARDS\nERG 26:\nsewers. Runoff to sewer may create fire or explosion hazard.\nFIRE OR EXPLOSION - Flammable/combustible material; may be ignited by heat, sparks or flames. Vapors may travel to a source of Ignition and flash back. Container may explode in heat of fire. Vapor explosion hazard indoors, outdoors or in\nHEALTH HAZARDS. - May be poisonous if inhaled, swallowed or absorbed through skin. Vapors may cause dizziness or suffocation. Contact may irritate or burn skin and eyes. Fire may produce irritating or polsonous gases. Runoff from fire con-\ntrol or dilution water may oive off poisonous gases and cause water pollution.\nEMERGENCY ACTION\nIsolate for 1/2 mile in all directions I tank, rall car or tank truck is involved in fire. CALL Emergency Response Telephone Number on Shipping Papars first. If Shipping Paper not avallable or ne answer, CALL CHEMTREC AT 1-800-424\nKeep unnecessary people away; isolate hazard area and deny entry. Stay upwind; keep out of low areas. Positive pressure self-contained breathing apparatus (SCBA) and structural firefighters' protective clothing will provide limited protection\n9300, If water pollution occurs, notify the appropriate authorities.\nloye container trom fire area if you can do it without risk. Apply cooling water to sides of containers that are exposed to flames until well after. fire is out. Stay away from ends of tanks. For massive fire in targo area, use unmänned hose hold\nRE-Small Fires: Dry chemical, CO2, water spray or alcohol-resistant foam. Do not use dry chemical extinguishers to control fires involving nitromethane or nipoethene. Large Fires: Water spray, fog or alcohol-resistant foar\nwitor monitor nozzles: i-this is Impossible, withdraw from area and let fire burn: Withdraw immediately in case of rising sound from venting safety dey ce or any discoloration of tank due.to tin\n'SPİLL OR LEAK - Shut off ignition sources, no flares, smioking or flames ih hazard area: Stop leak if you cari do it withöut risk. Water spray may redice vapor; but it may not prevent ignition coset spages. Bmalf Splus: Take up with sand i\nFIRST AID - Move victim to fresh air and call emergency medical care; if not breathing, give artificial respiration; if breathing is difficult, give oxygen. In case of contaçt with material, immediately flush skin or eyes with running water for at least\nother noncombustible absorbent material and place into containers for later disposal. Large Spills: Dike far ahead of liquid spill for later disposal.\n15 minutes. Wash skin with soap and water. Remove and isolate contaminated clothing and shoes at the site.\nPOTENTIAL HAZARDS\nERG 27:\nFIRE OR EXPLOSION = Flammable/combustible material: may be ignited by heat, sparks or flames. Vapors may travel to a source of ignition and flash-back. Container may explode in heat of fire. Vapor explosion hazard indoors, outdoors or in\nHEALTH HAZARDS - May be poisonous it inhaled, swallowed or absorbed through skin. Vapors may cause dizziness or suffocallon. Contact may Irritate or burn skin and eyes. Fire may produce irritating or poisonous gases. Runoff from tire con-\nsewers. Runoft to sawer-may. create fire or explosion hazard. Material may be transported hot.\ntrol or dilution water may cause pollution.\nKeep unnecessary people away; isolate hazard area and deny entry. Stay upwind; keep out of low areas. Positive pressure self-contaned breathing apparatus (SCBA) and structural firefighters' protective clothing will provide limited protection.\nEMERGENCY ÄCTION\nIsolate for 1/2 mile in all directions if tank, rail car or tank truck is Involved'in fire, CALL Emergency Response Telephone Number on Shipping Papers first. If Shipping Paper not available or no antwer, CALL CHEMTREC AT 1-800-424-\nMove container from fire area it you can do it without risk. Apply cooling water to sides of contalners that are exposed to flames until well after fire is out. Stay away from ends of tanks. For massive fire in cargo area, use unmanned hose holder\nFIRE - Small Fires: Dry chemical, CO2, water spray or regular foam. Large Fires: Water spray, fog;or regular foam.\n9300. If water pollution occurs, notify the appropriate authoritles.\nSPILL OR LEAK - Shut. off ignition sources: no flares, smoking or flames in hazard area. Stop leak if you can do it without risk. Water spray may reduce vapor, but it may not prevent ignition in closed spaces. Small Spills: Take up with sand or\nor monitor nozzles: if this is impossible, withdraw from area and lét fire burn. Withdraw immediately in case of rising sound from venting safety device or any discoloration of tank due to fire.\nother noncombustible absorbent material and place into containers for later disposal. Large Spille; Dike far ahead of liquid spill for later disposal.\nutes. Wash skin with soap and water. Remove and isolate contaminated clothing and shoes at the site.\nFIRST AID - Move victim to fresh air and call emergency medical care; if not breathing, give artificial respiration; if breathing is difficult, giø oxygen. i case of contact with material, imidiately flush eyes with running water for at least 15 min-\nPOTENTIAL HAZARDS\nERG 31\nFIRE OR EXPLOSION - Some of these materials may burn, but none of them Ignites readily: Material may be transported hot.\nHEALTH HAZARDS - Contact may cause burns to skin and eyes. Inhalation of asbestos dust may have a damaging effect on the lungs. Fire may, produce irritating or poisonous gases. Runoff from fire control or dilution water may cause pollutian:\nNumber on Shipping Papers first. If Shipping Paper not available or no answer, CALL CHEMTREC AT 1-860-424-9300. If water pollution occurs, notily the appropriate authoritles.\nred unnecessary pale away: isolate hazard area and deny entry. Postive prassure self-contained breathing apparatus (SCA) and strüctural trefighters' protective clothing will provide limited protection: CALL Emergeney Responso Telephone\nEIRE - Small Fires: Dry. chemical, C02, water spray or regular foam. Large Fires: Water spray, fog or regular foam.\nSPİLL OR LEAK - Stop leak if vou can do it without risk. Avoid inhalation of asbestos dust. Small; Dry Spillis: With clean shovel place matertal into clean, dry container and cover loosely; move containers from spill area. Large Spills: Dike far\nMave container from fire area if you can do it without risk. Do not scatter spilled material with high-pressure water streams. Dike fire control, water for later disposal.\naHAST AD - in case of contact with material, immediately flush eyes with running water for at least 15 minutes. Wash skin with soap ah water. Ramove and isolate contaminated clothing and shoes at the sile.\nahead of Jiquid spill for/ater disposal. Cover powder spill with plastic sheet or tarp to minimize spreading.\nPOTENTIAL HAZARDS\nERG 37\nHEALTH HAZARDS - It inhaled; may be harmful. Gontact may cause burns to skin and eyes: Fire may produce ritating or poisonous gases. Runoff from fire control or dilution water may cause pollution.\nFIRE OR EXPLOSION - Flammahle/combustible material. May ignite itself if exposed to air. May reighite after fire is extinguished. May burn rapidly with flare-burning effect. Runoff to sewer may create fire or explosion hazard.\nKeep unnecessary people away; isolate hazard area and deny entry. Stay upwind; keep out of low areas. Positive pressure self-contained breathing apparatus (SCBA) and structural firefighters\" protective clothing will provide limited protection.\nEMERGENCY ACTION\nFIRE - Some of these materials may react violently with water. Hydrosultite Fires: Use flooding quantities of water for any size fire: Small Fires: Dry chemical, soda ash, fime or sand Large Fires: Flood fire area with water trom a distance\nCALL Emergency Response Telephone Number on Shipping Papers Irat. It Shipping Paper not akallable or no anawer, CALL CHEMTREC AT 1-800-424-9300. IS water poilution occurs, notify and appropriate authorities.\naréa, use unmanned hose holder, or monitor nozzles; if this is impossible, withdraw from area and let fire burn.\nDo not get water inside container. Move container from fire area If you can do it without risk. Apply Cooling water to sides of containers that are exposed to flames until well after fire is out. Stay away from ends of tanks. For massive tire in cargo\nSPILL OR.LEAK - Do not touch or walk through spilled material; stop leak if you can do it without risk. Do not get water inside container. Smail Spills: Flush areas with flooding amounts of water. Large Spills: Dike liquid spill for later disposal\nFIAST AID - Move victim to fresh air and call emergency medical care. In case of contact with material, immediately flush skin or eyes With running water for at least 15 minutes. Remove and isolate contaminated clothing and shoes at the site:\nPOTENTIAL HAZARDS\nERG 60\nSHEALTH HAZARDS Contact causes burns to skin and eyes. I inhaled may be harmful: Fire may produce irritating or poisonous gases. Runoff from fire control or dilution water may cause pollution\nIKMERGENCY ACTION\nKeep unnecessary people away; isolete hazard area and deny entry. Stay upwind: keep.out of low areas. Positive pressure self-contained breathing apparatus (SCBA) and structural-firefighters' protective clothing will provide limited proteglion.\nCALL Emergency Response Telephone Numher on 8hipping Papers (Irst. It Shipping Paper not avalable or ne answer. CALL CHEMTREG-AT 1-800-424-9300, It water pollution occurs, notify the appropriate authorities.\nFiRE - Some of these materials may react violently with water. Small Fites: Dry chemical, CO2, water spray or regular foam. Large Fires: Water spray, fog or regular foam\n2: 3241\nSPILL OR LEAK * Do not touch or walk througlt spilled material: stop leak if you can do it without risk: 8mall Spills: Take-up with sand or other noncombustible absorbent material and place into containers for later disposal: Small Dry Spills:\nMove container from fire area if you can do it without risk. Apply cooling water to sides of containers that are exposed to flames until well after fire is out. Stay away from ends of tanks.\nFIRST AID Move victim to resh all, cal emergency medical care. Ih case of contact with material, irmediately flush skin or eyes with ginning water for at least 15 minutes. Remove and isolate contaminated clothing and shoes at the site. Keep\nWith clean shovel place material into clean, dry container and cover loosely, move containers from spill areas. Large Spllis: Dike far ahead of liquid spill for later disposal.\nvictim gulet and maintain normal body temperature.","truncated":false,"body_characters":21461}