# Fluor Hanford Waste Services — Hazardous Materials Safety Interpretation

- **operation:** document
- **citation:** 01-0248
- **title:** Fluor Hanford Waste Services — Hazardous Materials Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 2002-01-03
- **effective on:** Not available
- **summary:** 01-0248 response to Fluor Hanford Waste Services concerning 173.22.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-interpretation-01-0248.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-01-0248.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-01-0248
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2001/010248.pdf
**body:**

<<<PAGE 1>>>

of Transportation
U.S. Department
400 Seventh St., S.W
Washington, D.C. 20590
Research and
JAN 3 2002
Speciai Programs
Administration
Mr. Paul W. Martin
Ref. No. 01-0248
Fluor Hanford Waste Services/
Waste Management Project
P.O. Box 700
T3-04 • MO-279, 200 West Area
Richland, WA 99352-0700
Dear Mr. Martin:
This responds to your facsimiles and telephone conversations with staff members of this office
on the correct classification under the Hazardous Materials Regulations (HMR; 49 CFR Parts
hese lamps will be transported in bulk, and that many will be crushed as they are packaged
71-180) of high-pressure, sodium-vapor lamps being transported for disposal. You state that
I apologize for the delay in responding and any inconvenience it may have caused.
The two material safety data sheets (MSDS) you provided describe one lamp as containing the
following materials:
Chemical Name
Percent by Weight
Barium compounds
0.02<0.1
Lead solder
0.1<1.1
Sodium
0.003<0.01
Mercury
0.01<0.05
Lead Borosilicate Glass
30-75
Aluminum Oxide
<15.
The second lamp contains the following materials:
Chemical Name
Percent by Weight
Sodium
<0.01
Mercury
<0.02
Lead
no data given.
Neither MSDS describes the lamps as meeting an HMR hazard class or provides a protocol for
transporting crushed lamps in bulk. One MSDS states the sodium in the lamps may produce heat
when in contact with water, but the amount of sodium in a single lamp is so small it generally
presents no hazard. Both MSDS's prescribe methods for handling mercury vapor, lead dust, and
other chemicals and materials the lamps contain.
173.22

<<<PAGE 2>>>

Under § 173.22, it is the shipper's responsibility to determine the hazard class for a
hazardous material. This office does not perform that function. However, based on the
information you provided, we agree with your determination that a bulk package filled
with the crushed lamps would contain a sufficient amount of hazardous material to meet
the definition of a Division 4.3 material in § 173.124. You should also determine if the
package contains a sufficient amount of lead, mercury, or sodium to meet the definition in
§ 171.8 for a hazardous substance. Further, we agree with your determination that an
uncrushed lamp, provided it is not packaged with or contaminated by material from a
crushed lamp, is not regulated as a hazardous material under the HMR.
I hope this information is helpful.
Sincerely,
Transportation Regulations Specialist
Office of Hazardous Materials Standards
2

<<<PAGE 3>>>

09/24/2001 MON 13:53 FAX 509 372 0437
200W WASTE SERVICES
41001
Edmonson
3173.21
FLUOR HANFORD
3173.164
WASTE SERVICES
WASTE MANAGEMENT PROJEC 5173.124
Classification
MANAGER. L. T. BLACKFORD
01-0248
FACSIMILE TRANSMITTAL SHEET
TO: EILEEN EDMONSON
FROM: PAUL W. MARTIN, ECO
FAX NUMBER: 202-366-3012
DATE: SEPTEMBER 24, 2001
NAME/COMPANY: DOT HOTLINE
NAME/COMPANY: WASTE SERVICES
PHONE NUMBER: 202-366-4481
PHONE NUMBER: 376-6620
(509)
RE: REFAX OF MARCH 15, 2001 FAX
PAGES INCLUDING COVER: (7)
FOR SODIUM VAPOR BULB MSDS
Notes/Comments:
Per our telephone conversation on Friday, September 21, 2001, attached
is the fax from March 15, 2001. The cover page of the original fax also is
included.
And just as a refresher, Charles Te stated that uncrushed sodium vapor
lamps would be nonregulated per DOT. However, crushed bulbs would
be subject to 173.21. "Forbidden materials and packages". (I was thinking
that the crushed and un-reacted bulbs would be, at worse, 4.3,
dangerous when wet materials).
Thanks for your help,
Paul W. Martin
Env. Compliance Officer
POST OFFICE BOX 700
T3-04 • MO-279, 200 WEST AREA
RICHLAND, WASHINGTON
99352-0700

<<<PAGE 4>>>

09/24/2001 MON 13:54 FAX 509|
372 0437
200W WASTE SERVICES
4002
FLUOR HANFORD
WASTE SERVICES
WASTE MANAGEMENT PROJECT
MANAGER, L. T. BLACKFORD
FACSIMILE TRANSMITTAL SHEET
TO: EILEEN EDMONDSON
FROM: PAUL W. MARTIN, ECO
FAX NUMBER: 202 366-3012
DATE: MARCH 15, 2001
NAME/COMPANY: DOT HOTLINE
NAME/COMPANY: WASTE SERVICES
PHONE NUMBER:
PHONE NUMBER: 376-6620
RE: SODIUM VAPOR BULB MSDS
PAGES INCLUDING COVER: (6 )
Notes/Comments:
Per our telephone conversation just now, attached are the two MSDSs for
sodium vapor lamps. I confirmed with a co-worker that the crushec
sodium vapor lamps gave off 1 to 2 inch flames when contacted with
water. The sodium was in a solid state according to the co-worker who
witnessed the deactivation of the lamps.
This reaction conflicts with a manufacturer's claim concerning no DOT
applicability to sodium vapor lamps.
Thanks for you help.
•
2983
Paul W. Martin
Env. Compliance Officer
POST OFFICE BOX 700
T3-04 • MO-279, 200 WEST AREA
RICHLAND. WASHINGTON 99352-0700
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