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Use of a technical name when not required

Regulation

172.202

Regulation summary

Section 172.202(d) establishes the requirement for the use of technical names on shipping papers.

Question/Dilemma

In this scenario, a shipper inquires if it is acceptable to use a technical name after the proper shipping name even though it is not required. The shipper explains that 172.101(b)(4) states that when the letter “G” is in Column 1 of the HMT, a technical name in parenthesis is required with the basic description. However, the shipper’s material, UN1987 Alcohol, n.o.s., does not have a “G” in Column 1 of the HMT.

In this interpretation, PHMSA addresses if it is acceptable to have the technical name even though there is no “G” in Column 1 of the HMT.

Interpretation summary

In interpretation Ref. No. 23-0056, PHMSA advises that the HMT has several entries that do not include the letter “G” in Column 1 of the HMT, such as “UN1987 Alcohol n.o.s.” However, as provided in 172.202(d), technical and chemical group names may be entered in parenthesis between the proper shipping name and hazard class or following the basic description. PHMSA’s opinion is that the addition of the text, “(Denatured Alcohol and Ethanol)” in association with the basic description as provided in the example is an acceptable description of the hazardous material on a shipping paper.