Waste Technology Services Inc. — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 400 Seventh Street. S.W Research and Washington, D.C 20590 Special Programs Administration FEB 8 2000 Mr. David J. Passuite Waste Technology Services Inc. Ref. No. 00-0014 6 Forest Park Drive Farmington, CT 06032 Dear Mr. Passuite: This is in response to your letter concerning the requirements for lab pack shipments under the Hazardous Materials Regulations (HMR; 49 FR Parts 171-180). Specifically, you requested clarification on the marking requirements when a lab pack contains a material listed in the hazardous materials table (HMT) in § 172.101 with a plus (+) sign in column one (e.g., Benzaldehyde) and whether these materials may be lab packed with other hazardous materials. You also ask about the proper method of describing this material on a uniform hazardous waste manifest and hazardous waste labels required by the Environmental Protection Agency (EPA). The lab pack exception in §. 173.12(b) provides relief from specification packaging if packaged in accordance with the section and allows the shipper to use a generic name to represent compatible materials in the same hazard class in place of specific chemical names when packaged in the same outer packaging. Since Benzaldehyde has a "t" sign in column one, that name is fixed and cannot be replaced with a generic shipping name. In this case, the material may be packaged with the other compatible hazardous materials. However, the specific shipping name must be marked on the outside packaging in addition to the generic description for the other hazardous materials in the lab pack and listed separately on the shipping paper. Further requirements for lab packs are found in § 173.12(b). Since the hazardous waste manifest serves as the shipping paper, the requirement to describe Benzaldehyde separately applies when using a hazardous waste manifest. Your question concerning the EPA requirement for hazardous waste labels would best be answered by the EPA. You can contact the RCRA, EPCRA, and Superfund hotline at 1-800-424-9346. I hope this satisfies your request. Sincerely, Jeho Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 173.12 000014 -#

Page 2-JAN. 10.2008 10:24AM WASTE TECHNOLOGY SER NO.968 P.2/3 wIs Johnsen WASTE TECHNOLOGY SERVICES ING. $173.12 00 - 0014 January 10, 2000 Mr. Edward T. Mazzullo Director of Hazardous Materials Standards United States Department of Transportation Research and Special Programs Administration Fax (202)366-3012 Dear Mr. Mazzullo: I would like to get a written response from your office on the following DOT issue. Ref. No. 99-0145 (attached), a material with a fixed shipping name "may be lab packed According to a response letter from Thomas G. Allan to Bradford A. Gagton on 6/28/99, with other materials, as permitted by 173.12(b), but the name of the material must appear separately on the shipping paper and package markings". To clarify, does this mean that Benzaldehyde may be lab packed with other non- regulated materials only? If not, can this material be lab packed with other compatible class 9 materials? This would result in two distinct shipping descriptions for the same container, so do we attach two different hazardous waste labels, and if so, how do we prepare the manifest ("the name of the material must appear separately on the shipping paper")? Thank you in advance for your help on this matter. Sincerely, David J. Passuite WASTE TECHNOLOGY SERVICES, INC. Corporate Office: 640 Park Place, Niagara Falls, New York 14301 Telephone 716-282-4100 • Fax 716-282-6986 6 Forest Park Drive • Farmington, CT 06032 • Telephone (860) 677-1146 • Fax (860) 677-4979 2025 E. Main Street, Suite 101 • Flchmond, VA 23223 • Telephone (804) 649-0700 • Fax (804) 649-2360 www.wtsonline.com -#