Clean Venture, Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration MAR - 4 2011 1200 New Jersey Ave. SE Washington. D.C. 20590 Mr. Roy H. Swartz Manager of Regulatory Compliance Clean Venture, Inc. 138 Leland Street Framingham, MA 01702 Ref. No.: 10-0256 Dear Mr. Swartz: This responds to your November 19, 2010 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You have provided an example of a hazardous waste manifest. Column 9B of the manifest contains the following proper shipping description "RQ, Waste Trichloroethylene, 6.1, UN1710, PGIII." Column 10 includes the number and type of packages "6 DMlDF," where DM stands for metal drum and DF stands for fiber drum. In column 14, additional information is provided "Line 4 - 4DM, 2DF". Specifically, you ask iftwo types of packages (e.g., DMlDF) entered in association with a single basic description for a hazardous material would satisfy the shipping paper requirement to list the number and type ofpackages as part of the shipping description. The answer is yes. The HMR require the number and type of packages to be entered as part ofthe shipping description on a shipping paper (§ 172.202(a)(7)). The abbreviations DM and DF are used on hazardous waste manifests to indicate the presence of metal and fiber drums. Thus, the example you provided, which lists the number and type ofpackages in column 10 of a hazardous waste manifest as "6 DM/DF" for the shipping description satisfies the HMR requirement in § 172.202(a)(7). In addition, you asked about compliance with the Compliance, Safety, Accountability (CSA) 2010 program. The Federal Motor Carrier Safety Administration implements the CSA 2010 program. Information on CSA 2010 is available at the following website: http://csa.fincsa.dot.gov/. I trust this satisfies your inquiry. Please contact us if we can be of further assistance. Sincerely, ~5~ Ben Supko Acting Chief, Standards Development Branch Standards and Rulemaking Division#

Page 2E"enenlau.h .. ,. S17t ~ .. "Lt- Clean venture Inc. RCl7.,udo ..') ~,,!~~~s+ Responsive Environmental Management Services November 19, 2010 Mr. Edward T. Mazzullo Director, Office of Hazardous Materials Standards U.S. DOTjPHMSA (PHH-10) 1200 New Jersey Avenue, SE East Building, 2nd Floor Washington, DC 20590 Re: Hazardous Waste Manifest Question CSA 2010 Dear Mr. Mazzullo On behalf of Clean Venture, Inc. (US DOT 200827), I would like to ask you what DOT's current position is relative to container type entries on the Uniform Hazardous Waste Manifest (box 10). Specifically, may two types of containers be referenced on a single line? The situation which commonly occurs in our business involves a generator having several drums of the same type of material, but using both metal and fiber drums (OM and OF). We have been putting "OM/OF" in box 10 (and noting in box 14 how many of each) in order to save time and manifest forms (when only one line remains on a manifest). This practice was deemed acceptable by our state environmental agency (MassDEP) and by the US DOT Hotline a couple of years ago. With the advent of the new CSA rules, we are requesting assurance that this practice would not be considered a violation in the cargo related category of the CSA 2010 system. Sincerely, Roy H. Swartz Manager of Regulatory Compliance 138 Leland Street· Framingham, MA 01702 508-872-5000 • FAX: 508-875'5271 www.cyclechem.com Corporate OfflC€: New Jersey TSDF: South Jersey Qfflce: Maryland Office: Massachusetts TSDF: Connectlart Qfflce: 201 Soutll First Street 217 Soulh First Street 600 Cenco Boulevard 2031 Inverness Avenue General Chemical One Dod< street Ellzabetll, NJ 07206 Elizabeth, NJ 07206 Clayton, NJ 08312 BalUmore, M D 21230 138 Leland Street Stamford CT 06902 856-863-8778 410-368-9170 Framingham, MA 01702 203-969-2800 908-354-0210 908-355-5800 508-872-5000 FAX: 203-969-2264 FAX: 856-863-3725 Fax: 410-368-9171 FAX: 908-354-9731 FAX: 908-355-0562 FAX: 508-875-5271#