Veolia Environmental Services — Hazardous Materials Safety Interpretation

Page 1U.S. Department 1200 New Jersey Avenue SE of Transportation Washington. DC 20590 Pipeline and Hazardous Materials Safety Administration SEP 0 8 2011 Ms. Jennifer Eberle Manager, Transportation Compliance Veolia Environmental Services 1 Eden Lane Flanders, NJ 07836 Reference No. 11-0127 Dear Ms. Eberle: This is in response to your May 26,2011 letter concerning the display ofthe "ORM-D" hazard class on a shipping paper for a "Consumer commodity." Specifically, you ask if it is pennissible to omit the hyphen between the letters "m" and "d" under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). The answer is no. Although the HMR permit a proper shipping name to appear on a shipping paper without punctuation marks (see § 172.101(c), it provides no such relief for the display of a hazard class. For your information, please note that the HMR is phasing out use of the ORM-D hazard class and it will no longer be permitted to be used in domestic transportation after December 31, 2013 (see 76 FR 3308, 1/19/2011, Docket No. PHMSA-2009-0126 (HM215K)). Various sections of the HMR will implement new limited quantity provisions in its place that will establish a standardized system for national and international multi modal transportation. Under this new system, consumer commodities will have the same provisions and requirements for international and national transportation as the approach for deminimis quantities, and excepted quantities, and will promote compliance, efficiency and consistent training and lower costs after implementation. I hope this satisfies your request. Sincerely, T. Glenn Foster Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division#

Page 2Edmon .soY) ~ 11 z. ,0 I Ci)VEOlIA ~ 112.·20l> eNVIRONMENTAL SERVices ~~L~Plnj ~er.s May 26,2011 Office of Hazardous Materials Standards Pipeline and Hazardous Materials Safety Administration Attn: PHH-I0 U.S. Department of Transportation East Building 1200 New Jersey Avenue S. E. Washington DC 20590-0001 1(- 01 t 1 RE: Request for Interpretation Regarding Display of the "ORM-D" Hazard Class on a Shipping Paper To Whom It May Concern: Veolia is requesting guidance from PHMSA regarding indication of the "ORM-D" hazard class on a shipping paper. Is it permissible to display "ORM-D" as "ORMD" (without the hyphen between the M and the D)? Your written response to this question is greatly appreciated. If you require any further information regarding this request please feel free to contact me at jennifer.eberle@veoliaes.com or 973-448-4209. Thank you, Jennifer Eberle Manager, Transportation Compliance Veolia ES Technical Solutions, LL.C. 1 Eden Lane, Flanders, NJ 07836 Jennifer.eberle@veoliaes.com (973) 448-4209#