PSC Environmental Services, LLC — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Ave., SE Washington, DC 20590 Mr. James V. Levitz PSC Environmental Services, LLC 6405 Thornridge Drive Avon, IN 46 123 Ref. No. 09-0 156 Dear Mr. Levitz: This responds to your July 1,2009, letter requesting clarification on assigning generic shipping descriptions to specific materials with a fixed description under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171 -1 80). Specifically, you ask whether the list of fixed description entries provided in your letter may also be assigned a generic shipping name under the provisions for lab packs in 5 173.12(b). In your letter, you reference a previous letter of clarification (Ref. No.07-0144; March 4,2008) in which we stated that it is permissible to package specific materials with a fixed description, such as aniline and phenol, under the lab pack provisions in 5 173.12(b), and use a generic shipping description in place of the specific fixed description. You note that there are additional entries, listed in your letter, that may also qualify under the fj 173.1 2(b) provisions. You ask whether these additional listed materials qualify for the use of the generic shipping description under the lab pack provisions in 8 173.12(b). The answer is yes. The additional materials with fixed shipping descriptions listed in your letter that meet the hazard class/divisions specified in 5173.12(b) may be transported using a generic shipping description instead of the fixed description as provided in paragraph (b)(l) of 5173.12. I hope this answers your inquiry. Since iCsa Charles E. Betts 'ef, Standards Development L Ofice of Hazardous Materials Standards#

Page 2U.S. DOT PHMSA Office of Hazardous Materials Standards Attn: PHH-10 East Building 1200 New Jersey Avenue, SE. Washington, DC 20590-0001 July 1, 2009 Re: Fixed Descriptions/Lab Packs Dear Director; I am inquiring about the proper guidance in lab packing materials with a fixed description. I n D.O.T. Interpretation Letter 07-0144 dated March 4, 2008, it explains that it is permissible to package specific materials with a fixed description (Aniline and Phenol) under the lab pack regulations (173.12(b)); and, use a generic shipping description in place of the specific fixed descriptions. I n addition to Aniline and Phenol, there are numerous other hazardous materials that could qualify under this interpretation. Can the following also be packaged in accordance with the lab pack regulations with the utilization of a generic shipping description in place of the fixed description? Please note, this list only includes those fixed description materials that would qualify under the lab pack regulations as identified in 173.12(b)(l) and (3). LLC 6405 Thornridge Dr. Avon, I N 46123 jlovitz@pscnow.com 317-281-5195#