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InstituteWhat Would you Do QuestionsHazmat SafetyFocus AreaShipping papers - HazmatShipping papers - HazmatEnglishAnalysisTransportationUSA

Can the shipping papers be riveted to the door?

Scenario: A hazardous material shipping paper is mounted permanently behind a clear plastic plate that is riveted to the driver’s door of a cargo tank motor vehicle (CTMV). The shipping paper cannot be removed without removing the rivets that affix the plate to the door.

The CTMV only transports a single commodity, and the carrier uses a permanent shipping paper as provided in 172.201(e). The CTMV contains emergency response information (ERI) that meets the requirements of Part 172 Subpart G which can be removed from the CTMV.

Question: Does this scenario meet the requirements for hazardous material shipping paper accessibility?

Click below to see answers.

Can the shipping papers be riveted to the door?: Answer

Answer: Yes. Section 177.817(e) of the Hazardous Materials Regulations (HMR) requires the shipping paper to be readily available to, and recognizable by, authorities in the event of accident or inspection. Provided the shipping paper storage requirements of 177.817(e)(2) are met and all information required by Subpart C of Part 172 is readily visible to a person entering the driver’s compartment, the permanent shipping paper mounted as described meets the intent of the HMR.

Although the HMR instructs carriers to maintain ERI in the same manner as shipping papers, the HMR expressly requires that, in accordance with 172.602(b)(2), ERI must be available for use away from the package containing the hazardous material and thus may not be carried in the same manner as the shipping paper described above.

shipping-papers-hazmat
Shipping papers - Hazmat
shipping-papers-hazmat
Shipping papers - Hazmat
InstituteWhat Would you Do QuestionsHazmat SafetyFocus AreaShipping papers - HazmatShipping papers - HazmatEnglishAnalysisTransportationUSA

Can the shipping papers be riveted to the door?

InstituteWhat Would you Do QuestionsHazmat SafetyFocus AreaShipping papers - HazmatShipping papers - HazmatEnglishAnalysisTransportationUSA

Scenario: A hazardous material shipping paper is mounted permanently behind a clear plastic plate that is riveted to the driver’s door of a cargo tank motor vehicle (CTMV). The shipping paper cannot be removed without removing the rivets that affix the plate to the door.

The CTMV only transports a single commodity, and the carrier uses a permanent shipping paper as provided in 172.201(e). The CTMV contains emergency response information (ERI) that meets the requirements of Part 172 Subpart G which can be removed from the CTMV.

Question: Does this scenario meet the requirements for hazardous material shipping paper accessibility?

Click below to see answers.

Can the shipping papers be riveted to the door?: Answer

Answer: Yes. Section 177.817(e) of the Hazardous Materials Regulations (HMR) requires the shipping paper to be readily available to, and recognizable by, authorities in the event of accident or inspection. Provided the shipping paper storage requirements of 177.817(e)(2) are met and all information required by Subpart C of Part 172 is readily visible to a person entering the driver’s compartment, the permanent shipping paper mounted as described meets the intent of the HMR.

Although the HMR instructs carriers to maintain ERI in the same manner as shipping papers, the HMR expressly requires that, in accordance with 172.602(b)(2), ERI must be available for use away from the package containing the hazardous material and thus may not be carried in the same manner as the shipping paper described above.

Answer
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