Guidanceguidance
98-0349
Monsanto Company — Hazardous Materials Safety Interpretation
Current as of source date Government source
RegulusPipeline researchRegulusPipeline research98-0349
Page 1- U.S.Department of Transportation 400 Seventh Street, S.W. Washington, D.C. 20590 Research and Special Programs Administration MAR I 5 1999 MI. William J. Briner Ref. No. 98-0349 Regulatory Affairs Manager Monsanto Company 800 N. Lindbergh Boulevard St. Louis, Missouri 63167 Dear Mr. Briner: This is in response to your letter dated November 5, 1998, regarding $ 172.201 (a) (1) (iii) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). specifically, you ask whether a shipping paper may have a column heading of "HM DG" (or some variation thereof), rather than a column heading The shipping paper requirément in $ 172.201 (a) (1) (iii) specifies that a shipping paper, containing both a regulated hazardous material and a non-regulated material, may identify the hazardous material by placing an "X" in a column captioned "HM." The column heading you describe in your letter would not be in compliance with the HMR. The "DG" column heading is not acceptable because it would be the use of a non-authorized abbreviation and non-authorized code. I hope this satisfies your request. Sincerely, Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards#
Page 2•= Monsanto - BAH §172.201 November 5, 1998 U.S. Department of Transportation Research and Special Programs Administration Office of Hazardous Materials Standards 400 Seventh Street, S.W. Washington, D.C. 20590 Attn: Mr. Thomas Allan Dear Mr. Allan: I am writing to request a written interpretation concerning 49 CFR 172.201 (a)(1)(iii), which allows an "X" to be placed before the proper shipping name in a column captioned "HM". Monsanto Company is designing a single shipping paper for use not only in the United States but also in other countries. One of our offices in another country has requested that the "HM" column heading be changed to HM DG "HM" corresponding to "hazardous materials" and "DG" corresponding to "dangerous goods". Please indicate if a column heading containing the letters "HM" on the first line and the letters "DG" immediately below it on the second line is in compliance with 49 CFR 172.201 (a)(1)(iii). If you have any questions concerning this, please call me at (314) 694-2999. Sincerely, William Or. Briner William J. Briner Regulatory Affairs Manager#
This material provides agency context. It does not replace binding regulatory text, and its legal effect depends on the underlying authority and facts.