Guidanceguidance
01-0300
Alaska Abatement Corporation — Hazardous Materials Safety Interpretation
Current as of source date Government source
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Page 1of Transportation U.S. Department Washington, D.C. 20590 400 Seventh St., S.W. Special Programs Research and Administration JAN 9 2002 Mr. Arthur Solvang Ref. No. 01-0300 Alaska Abatement Corporation 520W. 58' Ave., Suite J Anchorage, AK 99518 Dear Mr. Solvang: This is in response to your letter dated November 27, 2001, requesting clarification on registration requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether a shipper is required to register if they offer for transportation or transport a Class 9 material in non-bulk packagings, where the transport vehicle is voluntarily placarded. The answer is no. A domestic shipment of Class 9 material in non-bulk packagings does not require a Class 9 placard (see § 172.504(f)(9)). Thus the shipper is not required to register. I hope this satisfies your request. Sincerely, Shan Fos.090 Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 172,504#
Page 2AK ABATEMENT CORP Fax: 907-563-0089 Nov 27 '01 12:18 P. 01 BAH Alaska 8107.601 Abatement Registration 01-0300 • Anchorage, AK 99518 520 W. 58th Ave., Suite J Corporation Fax: (207) 563-0089 Tel: (907) 563-0088 TO: Dianne Lavelle, Information Center FROM: Arthur Solvang Telephone: 202-366-4488 FAX: 202-366-3012 Tuesday, November 27, 2001 RE: Regulation Clarification Number of Pages: 01 On November 21", 2001 Alaska Abatement Corporation received nutificalion fum lie Alaska Department of Tranoportation Commorcial Vehicle Enforcement [Report number AKCF04055060] of the failure to display a 'US DOT HM registration number'. Subsequent review of the registration requirements does not clearly indicate that Alaska Abatement Corporation qualifies for registration. Please provide a written interpretation for our records. Alaska Abatement Corporation is an asbestos abatement contractor. Items which we transport to the landfill are packaged in labeled plastic bags and those bags are in tum sealed into a second bag. These bags at no time come close to the registration level of 468 cu ft. Each bag is labeled with the waste generator name and address along with the line: "ASBESTOS 9, NA2212 III, RQ". Bags are transported in a vehicle that has Class 9 placards on all four sides of the vehicle along with an approved disposal manifest. Thank you#
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