Guidanceguidance
06-0145
Virginia Polytechnic Institute and State University — Hazardous Materials Safety Interpretation
Current as of source date Government source
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Page 1U.S. Department of Transportation Washington, D.C. 20590 400 Seventh Street, S.W. Hazardous Materials Safery AUS Administration 1 2006 Mr. Frank Imperatore Hazardous Materials Manager Ref. No.: 06-0145 Virginia Polytechnic Institute and State University Environmental, Health and Safety Services 459 Tech Center Drive (0423) Blacksburg, VA 24061 Dear Mr. Imperatore: This is in response to your June 26, 2006 letter concerning the use of Special Permits Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your questions are (DOT-SP 8445 and DOT-SP 13192) and exceptions for lab packs in § 173.12 under the paraphrased and answered as follows: Q1. Special Permit DOT-SP 8445 authorizes combination packagings containing certain hazardous wastes or hazardous substances in more than one hazard class. May a acid, and acrylamide, be described under one generic description from the § 172.101 packaging prepared in accordance with DOT-SP 8445, which contains acetone, formic Al. No. Combination packagings containing individual receptacles with more than one class of hazardous material must be classed and described separately for markings and shipping papers. Q2. How must a packaging prepared in accordance with DOT-SP 13192 containing various Division 6 1 cyanide materials be classed and described (i.e., individual descriptions or one generic description)? A2. DOT-SP 13192 is not necessary for cyanide materials classed in Division 6.1. As provided by § 173.12(e), the provisions of § 177.848(c) do not apply to a cyanide Q3. Copper cyanide and nickel cyanide are Division 6.1 PG II materials and sodium cyanide and potassium cyanide are Division 6.1, PG I materials. Is it true that copper cyanide and 173.12 060145#
Page 2nickel cyanide may be offered for transportation and transported under the exceptions in § 173.12(b) and (e) but sodium cyanide and potassium cyanide may not? A3. Your understanding is correct. The exception for waste materials in § 173.12(b) does not apply to materials classed as Division 6.1 PG I unless transported under the terms of a special permit (e.g., DOT-SP 13192). In addition, the exception in § 173.12(e) requires waste cyanides and waste cyanide solutions or mixtures to be packaged ir. accordance with § 173.12(b). Therefore, waste cyanides classed as Division 6.1, PG I may not take advantage of the exception from segregation requirements in § 173.12(e). Q4. Sodium methylate is a Division 4.2 with a subsidiary hazard of Class 8, PG II and Is it true that sodium methylate may be offered for transportation and transported under aluminum borohydride is a Division 4.2 with a subsidiary hazard of Division 4.3, PG I. the exceptions in § 173.12(b) and (e) but aluminum borohydride may not? A4. Your understanding is partially correct. The exceptions for waste materials in § 173.12(b) and (e) do not apply to materials classed as Division 4.2 PG I unless transported under the terms of a special permit (e.g., DOT-SP 13192). Section 173.12(e) provides an exception from segregation requirements for cyanides and acids; sodium methylate and aluminum borohydride are not considered to be cyanides or acids. I hope this information is helpful. If you have further questions, please do not hesitate to contact this office. Sincerely, Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards#
Page 3Wl VirginiaTech 459 Tech Center Drive (0423) Environmental, Health and Safety Services 540/231-2982 Fax: 540/231-3944 Blacksburg, Virginia 24061 www.ehss.vt.edu E-mail: imperato@vt.edu Pollack June 26, 2006 $ 173.12 Mr. Edward T. Mazzullo Hazardous Waste U.S. DOT/PHMSA (PHH-10) Director, Office of Hazardous Materials Standards 06-0145 Washington, D.C. 20590-0001 400 7th Street S.W. Mr. Mazzullo: I am requesting some clarification in regards to the use of Special Permits and 49CFR173.12. It is my understanding that it is the shipper's responsibility per 49CFR173:22 to properly classify and describe a hazardous material in accordance with 172 and 173. Since I am getting conflicting information from my hazardous waste disposal vendors, and want to nake sure that Virginia Tech is compliant with the hazardous material regulations, 1 am requesting assistance from your office. Special Permit (DOT-SP 8445) Special Permit (DOT-SP 8445) allows the grantee to transport various liquid or solid hazardous substances and hazardous wastes packed in inside plastic, glass, earthenware or metal containers, not exceeding one-gallon capacity, over-packed in a JN specification 1A2 or 1B2 metal drum, a UN 1G fiber drum or a UN1H2 plastic drum not exceeding 220 liters (55-gallon) nominal capacity only for the purposes of disposal, re-packing or re-processing. Virginia Tech generates the following material as waste for offsite shipment: acetone (1 gallon), formic acid (2 litters) and acrylamide (100 grams). Special Permit (DOT-SP 8445), which of the following is the correct proper shipping If these items were packaged in one outer package (drum) as per the requirements of description for the outer package? A. "Waste Flammable liquid, toxic, corrosive, n.o.s., 3 (6.1, 8), UN3286, PG II, (acetone, formic acid, acrylamide) (DOT-S 8445)" Or Invent the Future VIRGINIA POLYTECHNIC INSTITUTE AND STATE UNIVERSITY An equal opportunity, affirmative action institution#
Page 4B. "Waste Acetone, 3, UN1090, PG II (DOT-SP 8445)" "Waste Formic acid, 8, UN1779, PG II (DOT-SP 8445)" "Waste Acrylamide, solid, 6.1, UN2074 PG II (DOT-SP 8445)-Toxic" Special Permit (DOT-SP 13192) hazardous materials in lab packs and non-bulk packages, and provides relief from Special Permit (DOT-SP 13192) allows the grantee to transport in commerce of certain segregation requirements and certain marking requirements subject to the packaging and safety measures prescribed herein. Virginia Tech generates the following material as waste for offsite shipment: sodium cyanide (500 grams), potassium cyanide (500 grams) and brucine (250 grams). requirements of Special Permit (DOT-SP 13192), which of the following is the correc f the sodium cyanide and potassium were packaged in one outer package as per the proper shipping description for the outer package? A. "Waste Cyanides, inorganic, solid, n.o.s., 6.1, UN1588, PG I, (Sodium cyanide, Potassium cyanide) (DOT-SP 13192)-Toxic " Or B. "Waste Sodium cyanide, solid, n.o.s., 6.1, UN1689, PG I, (DOT-SP 13192)-Toxic Toxic" "Waste Potassium cyanide, solid, n.o.s., 6.1, UN1680, PG I, (DOT-SP 13192) - If the sodium cyanide, potassium cyanide, and brucine were packaged in one outer package as per the requirements of Special Permit (DOT-SP 13192), which of the following is the correct proper shipping description for the outer package? A. "Waste Toxic solid, inorganic, n.o.s., 6.1, UN3288, PG I, (Sodium cyanide, Potassium cyanide, Brucine) (DOT-SP 13192) - Toxic" Or B. "Waste Sodium cyanide, solid, n.o.s., 6.1, UN1689, PG I, (DOT-SP 13192) - Toxic" Toxic" "Waste Potassium cyanide, solid, n.o.s., 6.1, UN1680, PG I, (DOT-SP 13192)- "Waste Brucine, 6.1,UN1570, PG I, (DOT-SP 13192) -Toxic" VIRGINIA POLYTECHNIC An equal opportunity, affirmative action institution INSTITUTE AND STATE UNIVERSITY#
Page 549CFR173.12 It is my understanding that cyanide waste like copper cyanide and nickel cyanide may be packaged and shipped per 49 CFR173.12 (b) and 49 CFR173.12 (e) but sodium cyanide and potassium cyanide may not. Is this correct? materials and prohibited per 49 CFR 173.12 (b)(3) while copper cyanide and nickel My understanding is that both sodium cyanide and potassium cyanide are 6.1 PG | cyanide are 6.1 PG II materials and are not prohibited. It is my understanding that Class 4.2 waste Sodium methylate may be packaged and not. Is this correct? shipped per 49 CFR173.12 (b) and 49 CFR173.12 (e) but Aluminum borohydride may CFR 173.12 (b)(3) while sodium methylate is 4.2 PG II material and is not prohibited. My understanding is that aluminum borohydride 4.2 PG 1 material and prohibited per 49 Your prompt reply would be greatly appreciated. I thank you for your assistance in this manner. Frank Imperatore, CHMM Hazardous Material Manager VIRGINIA POLYTECHNIC INSTITUTE AND STATE UNIVERSITY An equal opportunity, affirmative action institution#
This material provides agency context. It does not replace binding regulatory text, and its legal effect depends on the underlying authority and facts.