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Interpretation Response #10-0036

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date: 12-02-2010
Company Name: Dangerous Goods Declaration, Inc., and DGD Transport, Inc.    Individual Name: Mr. Luis Lopez
Location state: FL    Country: US

View the Interpretation Document

Response text:

December 2, 2010



Mr. Luis Lopez
Dangerous Goods Declaration, Inc.,
and DGD Transport, Inc.
2030 NW 95th Street
Miami, FL 33147

Reference No. 10-0036

Dear Mr. Lopez:

This is in response to your e-mail requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to shipping papers. Specifically, you ask whether a hazardous materials shipment offered or intended for transportation by aircraft that contains more than one package must use the plural form to describe the type of package in a shipping description on a shipping paper. You further ask whether the package type can be expressed in singular form if the correct number of packages is provided in the description. In addition, you note that § 172.202(a)(7) states that abbreviations may be used to indicate a packaging type. We apologize for the delay in responding to your inquiry and any inconvenience this may have caused.

The answer is yes. If more than one package is included in the shipping description and the number and types of packages in a description are correct, the type of package may be expressed in singular form (e.g., 12 box or 4 cylinder). Section 172.202(a)(7) requires that a package"s "number" and "type" be indicated in a shipping description, and provides examples in parentheses of both the singular and plural form of a package type (e.g., cyl., cylinder, and 12 drums), but does not require that the package type be expressed in plural form. This is consistent with § 171.9, Rules of Construction, which states "[w]ords imparting the singular include the plural""

I hope this satisfies your request.


T. Glenn Foster
Chief, Regulatory Review and Reinvention
Standards and Rulemaking Division

172.202(a)(7), 171.9

Regulation Sections

Section Subject
§ 172.202 Description of hazardous material on shipping papers