Basic Description on a Shipping Paper with "No Additional Information Interspersed"
Pipeline and Hazardous Materials Safety Administration · May 27, 2010 · Reference No. 10-0076
Interprets: 49 CFR § 172.202
Reggie’s quick take
A shipper asked whether labeling the parts of a shipping paper's basic description, such as "UN Number," "Proper Shipping Name," "Packaging Group," and "Hazard Class," inside the description sequence meets § 172.202(b). PHMSA says no. The basic description must run in order with no extra information mixed in. The only exceptions are the word "Class" or "Division" before the hazard class number under § 172.202(a)(3)(i), and a technical or chemical group name in parentheses between the proper shipping name and the hazard class under § 172.202(d). Category titles are not allowed.
Written by AI (Claude) on Oct 22, 2026. Robots make mistakes and leave things out, so the letter below is what counts. Not legal advice.
This responds to your March 31, 2010 letter regarding shipping paper description requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask for clarification of the requirement in § 172.202(b) that the basic description on a shipping paper must be shown in sequence with "no additional information interspersed."
Your letter includes copies of shipping papers with additional wording interspersed in the basic description. The basic descriptions include category titles for the component parts of the basic description interspersed within the basic description sequence such as "UN Number," "Proper Shipping Name," "Packaging Group," and "Hazard Class." You ask whether the formats used on the shipping papers comply with § 172.202(b).
The answer is no. Except for provisions that allow for additional information to be included in the basic description sequence, no additional information may be interspersed in the basic description. For example, § 172.202(a)(3)(i) allows the words "Class" or "Division" to precede the hazard class or division number(s) in the basic description sequence and § 172.202(d) allows the technical or chemical group name to be entered in parentheses between the proper shipping name and hazard class in the basic description sequence. Otherwise, no additional information such as category titles may be interspersed in the basic description sequence.
A letter of interpretation applies the regulations to the facts the requester described. It isn’t a regulation and isn’t legal advice. The agency’s copy.