Onyx Environmental Services, LLC — Hazardous Materials Safety Interpretation

Page 1.S. Departmen f Transportatio Washington, D.C. 20590 400 Seventh Street, S.W. Pipeline and Administration Hazardous Materials Safety DEC -5 2005 Ms. Jennifer Eberle Ref. No. 05-0277 Manager, Transportation Compliance Onyx Environmental Services, LLC 1705 Route 46 West, Unit #2 Ledgewood, NJ 07852 Dear Ms. Eberle: This is in response to your letter dated October 24, 2005, and subsequent telephone conversation with a member of my staff requesting clarification of the proper shipping name requirements of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171- 180). Specifically, you inquired about the proper placement of italicized words within a shipping description. Italicized information may be utilized in addition to the proper shipping name (§172.101(c)(2)). The overall orientation of additional information is optional; however, the preferred sequence for the proper shipping name is established by the Hazardous Material Table (HMT) (§ 172.101(c)(4))). In the example you provide, a shipper is preparing adhesives for transportation and includes italicized information on the shipping paper. In that case both "Adhesives, containing a flammable liquid, 3, UN 1133, PG I" or "Adhesives, 3, UN 1133, PG I, containing a flammable liquid" are acceptable proper shipping descriptions. The first description utilizes the sequence found in the HMT and is preferred. I hope this satisfies your request. Sincerely, Chief, Standards Development Office of Hazardous Materials Standards 171.8 172, 101(c) 050277#

Page 2-ONT BAH ENVIRONMENTAL SERVICES § 171,8 October 24, 2005 $172,101 (J Mr. Edward Mazzullo, Director Shipping Name 05-02.77 Dear Sir, I am writing this letter to obtain an interpretation that describes the proper placement of italicized italics are not part of the proper shipping name, but may be used in addition to the proper shipping words within a shipping description. As indicated in §§171.8 and 172.101(c), it is clear that words in It is my interpretation that when including the italicized words within a shipping description, they hazard class as indicated in the Hazardous Materials Table: would be placed immediately following the proper shipping name and immediately preceding the Adhesives, containing a flammable liquid, 3, UN1133, PG I Mas provide if is nocret, ense prove taritation hat etic went one profalicized placement would be. Thank you for your assistance, Jennifer Eberle Onyx Environmental Services, LLC Manager, Transportation Compliance 1705 Poste 46 West, Unit #2 Önyx Environmental Services, L.l.C. 1 edgawood, N./ 07852 (373) 448-4203 Jaberie@cnyxee.com VEOLIA has rongement#