Oak Ridge National Laboratory — Hazardous Materials Safety Interpretation

Page 1Transportatic S. Departmer Wastington, D.C. 20590 400 Seventh Street, S.W. Pipeline and Administration Hazardous Materials Safety SEP 12 2006 Mr. Herb Debban Director, Facilities and Operations Directorate Reference No. 06-0168 Oak Ridge National Laboratory P.O. Box 2008 Oak Ridge, Tn 37831-6257 Dear Mr. Debban: This is in response to your June 26, 2006 letter concerning how to select the correct proper shipping name for a lab pack containing two types of Division 4.1 (flammable sol: d) materials under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). In your example, you state the outer package contains five bottles, three that contain organic compounds and two shipping name without the word "organic" or "inorganic" on the Hazardous Materials Table that contain inorganic metal powders. Because there is no generic flammable solid proper (HMT; § 172.101), you ask if you must choose one of these names to describe the lab pack or if a generic proper shipping name for each material must be used. The lab pack exception in § 173.12(b) allows a shipper to use a generic proper shipping name in same hazard class in the same outside packaging provided the items are packaged, described, and place of specific chemical names to represent two or more compatible waste materials of the transported in accordance with this section. If an appropriate generic proper shipping name to specific proper shipping name for each material contained within the package may be used. describe all the materials within the package is not provided in the HMR, either the generic or I hope this information is helpful. Mattle I at Hattie L. Mitchell, Chief Regulatory Review and Reinvention Office of Hazardous Materials Standards 172.10/ 060168 173.12 (6)#

Page 2OAK RIDGE NATIONAL LABORATORY MANAGED BY UT-BATTELLE FOR THE DEPARTMENT OF ENERGY Oak Ridge, TV 37831-08 Fax: (865) 241-7610 (865) 241-7612 Email: debbanh@ornlogov Edmonson June 26, 2006 Pipeline and Hazardous Materials Safety Administration U.S. Department of Transportation 06-0168 400 Seventh Street, S. W. Washington, DC 20590 Dear Sir or Madam: Our company has a need to prepare a lab pack of flammable solids with five inner bottles. Three contain organic compounds and two contain inorganic metal powders. The 1996 Department of Transportation (DOT) interpretation (96-1019) addresses mixtures (Question 1) and lab packs containing both organic and Shipping Name (PSN) that does not reflect "organic" or "inorganic." DOT cites "Corrosive liquid, n.o.s." inorganic materials (Question 2). For lab packs, the interpretation advises use of a more generic Proper (except one with a 5.1 subsidiary hazard) have "organic" or "inorganic" as part of the entry. Would it be as an example of this approach. However, all of the currently available generic flammab e solid PSNs of organics vs. inorganics? Alternately, would it be necessary to use two PSNs for this lab pack? appropriate to select the generic PSN based on inner container quantities (i.e. mass, volume, or piece count) n.o.s. options, could we follow the same rationale as mentioned above for flammable solids? Also, since the proper shipping names for Toxic liquids and Toxic solids also have only organic or inorganic Your assistance in this matter is greatly appreciated. If you have any questions please contact Jeff H. Shelton at (865) 576-6401. Sincerely, festore , Facilities and Operations Directorate erb Debban, Director HLD:bjc CC: J. M. Forstrom M. G. Branton, DOE-ORO J. W. Smith J. H. Shelton J. B. Roberto J. E. Powell J. Wadsworth - RC D. M. Willaford, DOE-ORO C. A. Schrof#