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U.S. Department
of Transportation
Pipeline and Hazardous
Materials Safety
Administration
Mr.
Clifford Croft
Kajuligan Corporation
1533 Kirkwood Drive
Geneva, IL 60134
Reference No. 15-0189
Dear Mr. Croft:
JAN
0 8
2016
1200 New Jersey Avenue, SE
Washington, D.C. 20590
This responds to your September 21, 2015 email requesting clarification
of
the shipping paper
requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).
Specifically, you ask whether a multi-page shipping paper, consisting
of
a bill
of
lading and
a.Ii
attached shipping paper containing the hazardous material information, satisfies the shipping
paper requirements. You state that you use an orange tab to identify the shipping paper
containing the hazardous material information.
Under the HMR, a shipping paper means a shipping order, bill
of
lading, manifest or other
shipping document serving a similar purpose and prepared in accordance with 49 CFR part 1 72
subpart
C.
See § 171.8. In accordance with § 172.201 ( c ), a shipping paper may consist
ofmore
than one page,
if
each page is consecutively numbered and the first page bears a notation
specifying the total number
of
pages included
in
the shipping paper. For example, "Page 1
of
4
pages." Section 172.201(a)(l) also prescribes that,
ifa
hazardous material and non-hazardous
material are listed
on
the same shipping paper (single-
or
multi-page), the hazardous material
information must either be listed first, entered in a contrasting color,
or
"identified by the entry
of
an
'X'
placed before the basic shipping description .. .in a column captioned
'HM'.''
In
addition, 49 CFR 177 .817 ( e )(1) requires that the driver and carrier clearly distinguish a
hazardous material shipping paper
if
it
is carried with other shipping papers, bills
of
lading or
documents
of
any kind. The shipping paper containing hazardous materials must be
distinguished by either distinctly "tabbing" the shipping paper or having it appear first.