PHMSA Response Letter

---

Mr. John Foglio
Manager, Hazardous Materials
Transportation Safety
Evonik Degussa Corporation
379 Interpace Parkway
Parsippany, NJ 07054-0677

Ref. No.: 08-0155

Dear Mr. Foglio:

This responds to your letter regarding the requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) for placement of the words “Limited Quantity” or “Ltd Qty” on a preprinted shipping paper.

According to your letter, your company uses a computer generated, preprinted shipping paper to describe its hazardous materials offered for transportation in commerce. The manner in which your computer generated system is set up, “Limited Quantity” appears after the basic description, but sometimes not directly after it. Often times, technical names of marine pollutants and hazardous substances appear directly after the packing group and before the words “Limited Quantity”. Sometimes, safety phrases appear in the same position. For example, Stow away from foods or other phrases, such as the control and emergency temperatures, when applicable, may appear in the position between the packing group and “Limited Quantity”.

Currently, the basic description on a shipping paper must be shown in the following sequence: the proper shipping name, hazard class/division number, identification number, and packing group, if applicable (see § 172.202(a)). The description for a hazardous material offered for transportation as “Limited Quantity,” must include the words “Limited Quantity” or “Ltd Qty” following the basic description (see § 172.203(b)). A shipping paper may contain additional information concerning the material provided the information is not inconsistent with the required description. Unless otherwise permitted or required, additional information must be placed after the basic description (see §172.201(a)(4)).

Additional information, such as that prescribed by § 172.203 (e.g., hazardous substances or marine pollutants) or other additional information concerning a hazardous material must be placed after the basic description on a shipping paper, except that certain notations such as “RQ” may appear before the proper shipping name, and a technical name or chemical group name for a generic description may follow the proper shipping name. Shipping papers that are designed in columnar form may have the quantity shipped and type of packaging, e.g., “19 drums” entered before the basic description. Other information such as safety phrases or the control and emergency temperatures must be entered on the shipping paper after the basic description, which means in association with the basic description (i.e., its clear that the information applies to that description).

Although you did not provide a copy of your preprinted shipping paper, the sequence for “Limited Quantity” or “Ltd. Qty” and the “safety phrases” appearing after the basic description, in the manner described in your letter, are acceptable.

I hope this information is helpful. If we can be of further assistance, please contact us.

Sincerely,

Susan Gorsky
Acting Chief, Standards Development
Office of Hazardous Materials Standards

172.203, 172.202(a), 172.201(a)(4)