# New York State Department of Environmental Conservation Division of Solid and Hazardous Materials — Hazardous Materials Safety Interpretation

- **operation:** document
- **citation:** 03-0072
- **title:** New York State Department of Environmental Conservation Division of Solid and Hazardous Materials — Hazardous Materials Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 2003-05-07
- **effective on:** Not available
- **summary:** 03-0072 response to New York State Department of Environmental Conservation Division of Solid and Hazardous Materials concerning 172.101.
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- **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-03-0072.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-03-0072
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2003/030072.pdf
**body:**

<<<PAGE 1>>>

MAY
/ 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 2>>>

New 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 3>>>

Mr. 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
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