PHMSA letter of interpretation

Use of Abbreviations for Additional Shipping Information on a Shipping Paper

Pipeline and Hazardous Materials Safety Administration · Apr 2, 1975 · Reference No. 75-0002

PHMSA says to use caution with this letter.

Interprets: 49 CFR § 172.201, 49 CFR § 173.427, 49 CFR § 177.817

You asked in your March 21, 1975 letter whether your proposed "description to be shown on shipping papers" was in compliance with Section 177.817.

The regulation does not contain a restriction as to the placement or use of abbreviations for additional shipping information on a shipping paper. Therefore, such information may be placed before or after the description required by Sections 173.427 and 177.817. However, these sections do not permit the use of abbreviations in the required description.

Your attention is invited to a notice of proposed rule making under Docket No. HM-103 (Copy enclosed). Section 172.201 of the proposal would require hazardous materials to be described first.

If you have any further questions concerning this matter, please call upon me.

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.