Guidanceguidance
04-0177
Environmental Management & Controls, Inc. — Hazardous Materials Safety Interpretation
Current as of source date Government source
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Page 1U.S. Department OCT 21 2004 Research and of Transportation Washington, D.C. 20590 400 Seventh St., S.W. Special Programs Administration Ms. Gaye Nelson Ref. No. 04-0177 Assistant Manager 3106 S. Faith Home Road Environmental Management & Controls, Inc. Turlock, CA 95380 Dear Ms. Nelson: This is in response to your August 4, 2004 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if the statement "Limited quantity radioactive material," which is required to be included on the shipping paper in association with the basic description (§ 173.423), may be modified to read "Ltd lty radioactive material." A limited quantity Class 7 (radioactive) material, which is classed other than Class 7 is excepted from the requirements of S$ 173.422 (a), 172.203 (d), and 172.204 (c) (4) of the HMR if the entry "Limited quantity radioactive material" appears on the shipping paper in association with the basic description. Section 172.202 (b) permits the use of the abbreviation "Ltd Qty" including "Ltd Qty radioactive material" in association with the in place of "limited quantity" on a shipping paper. Therefore, basic description on a shipping paper would satisfy the shipping paper requirement of § 173.423. I hope this information is helpful. If you have further questions, please do not hesitate to contact this office. Sincerely, foda Chief, Standards Development Office of Hazardous Materials Standards 172.203(6) 040177#
Page 2ENVIRONMENTAL MANAGEMENT AND CONTROLS, INC. 3106 SOUTH FAITH HOME ROAD TURLOCK, CALFORNIA 95380 PHONE (800) 552-6121 E-MAIL:emctga@aol.com PHONE (209) 667-1102 FAX (209| 667-1563 ML August 4, 2004 BAH Mr. Edward T Mazzullo §112.203 (k) Director, Office of Hazardous Materials Standards 400 7* Street S.W. U.S. DOT/RSPA (DHM-10) Shipping Papers Washington, DC 20590-0001 202-366-3012 fax 04-0177 Dear Mr. Mazzullo: I am requesting a formal reply to my email of 7/29/04. Thank you, • Dany reeson Ms. Gaye Nelson Assistant Manager Environmental Management & Controls, Inc 3106S Faith Home Road Turlock, CA 95380 209-667-1102 phone 209-667-1583 fax EBSIL996D2 dee e0 to Do any#
Page 3Page 2 of 2 To: INFOCNTR <RSPA> Sent: Thursday, July 29, 2004 4:40 PM Subject: Limited Quantity we can abreviate. But if you look at 173.423 (b) Multiple hazards, it is written out. What is your If you are shipping Waste Flammable Liquid.....(Lty Qty radioactive material), according to 172.203 (b) interpretation? Ms. Gaye Nelson Thank you Assistant Manager Environmental Management & Controls, Inc 8/13/2004#
This material provides agency context. It does not replace binding regulatory text, and its legal effect depends on the underlying authority and facts.