OOSC, Part III, Item 1. Shipping Papers - General

Austin Powder Co.'s shipping paper is pre-printed with the various Haz Mat that we transport. At least on two occassions we received Out of Service violations for shipping papers when the driver omitted the number of packages and the quantity. The description included the Proper shipping name and ID number. According to the "NOTE" in the Out of Service Criteria it should not be an Out of Service Violation if the proper shipping name OR ID number is present. When I submit Data Q's the responses are No Action Taken. I need guidance and help.

I know shipping papers are an important resource for emergency responders, however in my past experience as an emergency responder, I normally was unable to locate shipping papers due to the accident and the cab being in disarray. If it was a serious crash with spillage, I always had to rely on placarding or marking for Haz Mat ID. With the requirement for a Safety Permit from FMCSA, it is imperative that Haz Mat carriers attempt to stay below the National average for Haz Mat Out of Service and receiving this type of Out of Service could result in Safety Permits not being renewed.

I would like to have either the "NOTE" in the Out of Service Criteria clarified or establish some type of recourse that a Carrier can utilize if Data Q responses from States can be appealed.