Weight on Shipping Papers

This is in response to your October 31, 1994 letter and subsequent telephone conversation with a member of my staff concerning the requirement to indicate the total quantity of a hazardous material on shipping papers in accordance with 49 CFR 172.202(a)(5). Specifically, for a refrigerator weighing 900 pounds which contains 4 pounds of ammonia, you asked whether the total quantity entered on the shipping paper should reflect 900 pounds or 4 pounds.

In accordance with § 172.202(a)(5), the total quantity for each hazardous material description may be indicated as net or gross mass, capacity, or as otherwise appropriate. Net mass is the weight of the contents within the packaging (i.e., 4 pounds). Gross mass is the weight of the packaging plus its contents (i.e., 900 pounds).