Guidanceguidance
03-0072
New York State Department of Environmental Conservation Division of Solid and Hazardous Materials — Hazardous Materials Safety Interpretation
Current as of source date Government source
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Page 1MAY / 2003 400 Seventh St., S.W. Washington, D.C. 20590 Mr. Paul R. Counterman, P.E. Director, Bureau of Hazardous Waste Management Ref No. 03-0072 New York State Department of Environmental Conservation Division of Solid and Hazardous Materials 625 Broadway Albany, NY 12233-7251 Dear Mr. Counterman: This is in response to your February 18, 2002 letter, requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) on the proper shipping name and appropriate packaging for industrial rags. Specifically, you request written confirmation that the proper shipping name should be"Solids containing corrosive liquid, n.o.s", "Solids containing flammable liquid, n.o.s." or "Solids containing toxic liquid, n.o.s." if any amount of corrosive, flammable or toxic liquids are present in the rags. In accordance with § 173.22, it is the responsibility of the shipper to select the shipping name that most accurately reflects the material being shipped. The shipper must also determine the packaging or container in an authorized packaging, including part 173 requirements, and that it has been manufactured, assembled, and marked in accordance with the HMR. The proper shipping names you listed can be used for the shipment and transportation of industrial rags containing various hazardous materials. The Hazardous Materials Table (HMT), § 172.101, provides Special Provisions for each of the proper shipping names: Special Provision 49 for corrosive liquids; Provisions state that this material may be transported under the above proper shipping names without Special Provision 47 for flammable liquids; and Special Provision 48 for toxic liquids. These Special first applying the classification criteria, provided there is no free liquid visible at the time the material is loaded or at the time the packaging or transport unit is closed. Authorized packagings are identified in §§ 173.212 and 173.240 for non-bulk and bulk packaging, respectively. Packaging exceptions are identified in §$ 173.154 and 173.151 for corrosive liquids and flammable liquids, respectively. I hope this information is helpful. If we can be of further assistance, do not hesitate to contact us. Sincerely, Debun Killio Delmer F. Billings Chief, Standards Development lo, Office of Hazardous Materials Standards 030072#
Page 2New York State Department of Environmental Conservation Bureau of Hazardous Waste Management, 8'* Floor Division of Solid and Hazardous Materials Foster 625 Broadway, Aibany, New York 12233-7251 Phone: (518) 402-8612 • FAX: (518) 402-9025 5173-101 Website: www.dec.state.ny.us Proper Dor. Shipping Name February 18, 2003 Mr. Edward T. Mazzullo Director Office of Hazardous Materials Standards U.S. DOT/RSPA (DHM-10) 400 7th Street S.W. Washington, D.C. 20590-0001 Dear Mr. Mazullo: received from staff at the Hazardous Materials Information Center (HMIC) regarding We would like to request written confirmation of some verbal guidance recently industrial rags/wipers picked up for laundering by commercial laundries from various businesses. and/or corrosive liquids, but generally no free liquids are visible in the containers During use, these cloth rags often absorb varying amounts of toxic, flammable, back to the industrial laundry. holding these rags at the time the material is loaded onto laundry trucks for transport of Staff at HMIC have indicated that these rags would have proper shipping names Solids containing corrosive liquid, n.o.s, Solids containing flammable liquid, n.o.s., or Solids containing toxic liquid, n.o.s, if any amount of corrosive/flammable/toxic liquids are present in the rags. We are requesting written confirmation that this correct. Some commercial laundries operating in New York are transporting cloth rags (and soiled clothing) containing varying amounts of corrosive, flammable, and toxic liquids in bags, and we need to know if these rags must be assigned one of the above proper shipping names.#
Page 3Mr. Edward T. Mazzullo 2. In addition, please advise what the appropriate shipping container would be for these rags. At this time, the cloth rags are being transported in bags. my staff, at (518) 402-8633 if you need further information from us. Thank you very much for your assistance. Please call me or William Yeman, of Sincerely, Paul 2. Coun - Le Director Paul R. Counterman, P.E. Bureau of Hazardous Waste Management Division of Solid & Hazardous Materials#
This material provides agency context. It does not replace binding regulatory text, and its legal effect depends on the underlying authority and facts.