Hazardous Materials Safety Interpretation 12-0023

Page 1u.s. Department 1200 New Jersey Avenue SE of Transportation Washington, DC 20590 Pipeline and Hazardous Materials Safety Administration MAR 072012 Mr. T. J. McCaustland Environmental, Safety, and Health Manager SSWSI-East Region 583 Highway 162 Covington, GA 30016 Reference No.: 12-0023 Dear Mr. McCaustland: This is in response to your January 12, 2012 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) as they pertain to overpacks. Specifically, you present a sc€nario where you ship multiple drums of various size containing EPA Hazardous Waste code 0001. The Reportable Quantity (RQ) for D001 is 100 pounds and none of the drums exceed 99 pounds. The drums are shrink wrapped to a pallet (overpacked) for shipment. You ask whether the overpack meets the definition of a package, causing the shipment to be classified as a hazardous substance. The answer is no. Multiple packages overpacked together do not meet the definition of a single package. Shrink wrapping the individual drums (packages) to a pallet is specifically cited as meeting the HMR § 171.8 definition of Overpack. Therefore the shipment as described would not be classified as a hazardous substance. I trust this satisfies your inquiry. Please contact us if we can be of further assistance. PL' Delmer'tl!fo Senior Regulatory Advisor Standards and Rulemaking Division#

Page 2• • •••• . SterlcycIe" ••• Specialty Waste Solutions U.S. DOT PHMSA Office ofHazardous Materials Standards Attn: PHH-I0 East Building 1200 New Jersey Avenue, SE. Washington, DC 20590-0001 I am seeking guidance on the applicability ofReportable Quantities to an overpack. We have sought the help ofthe Hazardous Materials Infonnation Center but have received conflicting responses. Or perhaps our questions were not identicaL Please refer to the question below and provide the proper guidance. Ifmultiple drums ranging in size from 2 gallons to 18 gallons Containing Flammable W aste EPA Hazardous Waste code DOOI with no one container exceeding 99lbs were shrink wrapped to a pallet and manifested as 1 CW would the RQ for DOOI apply? Essentially does the overpack meet the definition ofpackage and therefore hazardous substance as defmed in 171.8? Thank you for your time in assisting us in the safe transportation ofhazardous materials. T.J. M C Caustland Environmental, Safety, and Health Manager SSWSI-East Region 583 Highway 162 Covington, Georgia 30016 M: (770) 891-2531 F: (888) 240-4312 0: (678) 342-4279 ••• ••• Sterlcydo . . *.* '''''''~l'''"' O"~""" SSWSI Environmental, Safety, and Health 583 Highway 162 CovIngton, Georgia 30016 (678)342-4279 1#