World Environmental, Inc. — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 400 Seventh St., S.W. Washington, D.C. 20590 Research and Special Programs Administration OCT 12 2004 Mr. Mike Gilmore Reference No. 04-0010 World Environmental, Inc. 1026 Long Cove Road Gales Ferry, CT 06335 Dear Mr. Gilmore: This is in response to a request we received from Brian Grenier of your company concerning a follow-up to his question to the Hazardous Materials Information Center asking if the container type of a hazardous material must be indicated on the shipping paper under the Hazardous Materials Regulations (49 CFR Parts 171-180). You stated the answer you received in the center was that it was not required. We apologize for the delay in responding and any inconvenience this may have caused. The answer you received is incorrect. Section 172.202(a)(6) specifies that the number and type of package must be indicated on a shipping paper for a hazardous material transported in commerce. The type of packaging may be indicated by word description, such as "12 boxes" or "12 drums," and may include the packaging specification number, such as "6 1H1 drums." See the enclosed final rule. I hope this satisfies your request. Sincerely, Hathe z. Mitthell Hattie L. Mitchell, Chief Regulatory Review and Reinvention Office of Hazardous Materials Enclosure 040010 172:202#

Page 2Jan 14 04 11:52a Worid Environmental Inc 860 464 4005 p.2 Edmonson 5/72.202 W RLD Shipping Papers ENVIRONMENTAL HAZARDOUS WASTE MANAGEMENT. ENGINEERING AND CONSULTING - INCORPORATED 04- 00K 1026 Long Cove Road 1/14/04 Gales Ferry, CT 06335 Office: (860) 464-0341 Fax: (860) 464-4005 bgrenier@world8a.com Mr. Edward Mazzullo I use a hazardous waste manifest to ship waste but I am unable to find in the CFR where it references shipping a metal drum and a fiber drum on the same line of the shipping paper (manifest): So I called 1-800-HMR49-22 in regards to this question and they were helpful with giving me a verbal answer of D.O.T. does not require container type to be on the shipping paper. When I asked them if I can get that in writing they referred me to decision in writing. you. So I was hoping you would be able to aid me in this matter with giving me a If you have any questions please feel free calling me. When you reach a conclusion can you please fax and mail it to me? Thanks, Brian Grence Brian Grenier 12419 W. HAMPTON AVE., STE. 201 BUTLER, WISCONSIN 53007 PHONE: 414.790.1700 FAX: 414.790.1702#