{"operation":"document","citation":"15-0109","title":"US Ecology - Regional Office — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2015-08-31","effective_on":null,"summary":"15-0109 response to US Ecology - Regional Office concerning 171.8, 172.101, 172.203.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-15-0109.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-15-0109.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-15-0109","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2015/150109.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\n1200 New Jersey Avenue SE\nWashington, DC 20590\nPipeline and Hazardous\nAdministration\nMaterials Safety\nAUG 3 1 2015\nMr. Brian Kucharski\nDOT Compliance Manager\nUS Ecology - Regional Office\n17440 College Parkway, Suite 300\nLivonia, MI 48152\nReference No: 15-0109\nDear Mr. Kucharski:\nThis is in response to your June 4, 2015 email requesting clarification of the shipping\ndescription requirements on a shipping paper for hazardous wastes in accordance with the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your questions are\nparaphrased and answered below:\nQ1. Does the definition of a \"technical name\" in § 171.8 include the EPA's hazardous\nwaste codes?\nAl.\nThe answer is no. As defined in § 171.8, a technical name means a recognized\nchemical name or microbiological name currently used in scientific and technical\nhandbooks, journals, and texts. Generic descriptions are authorized for use as technical\nnames provided they readily identify the general chemical group, or microbiological group.\nExamples of acceptable generic chemical descriptions are organic phosphate compounds,\npetroleum aliphatic hydrocarbons and tertiary amines.\nQ2.\nDoes the following example satisfy the requirement in § 172.203(k) to include the\ntechnical name entered in parentheses in association with the basic description?\nUN1993, Waste Flammable Liquids, n.o.s., (D001), 3, PG II\n-Where \"DOOl\" is the technical name\nA2. See Al. The answer is no. Section 172.203(k) requires that unless otherwise\nexcepted, if a material is described on a shipping paper by one of the proper shipping names\nidentified by the letter \"G\" in column (1) of the §172.101 Hazardous Materials Table\n(HMT), the technical name of the hazardous material must be entered in parentheses in\nassociation with the basic description. The technical name entered in parentheses must be\nthe constituent(s) which makes the product a hazardous material. For UN1993, this would\nbe the constituents) which cause the material to be classed as a Class 3, flammable liquid.\n\n<<<PAGE 2>>>\n\nIs the exception from the requirement to include a technical name in association with\nthe basic description on a shipping paper prescribed in § 172.203(k)(2)(i) limited only to\nshipments offered under the entries \"NA3077, Hazardous waste, solid, n.o.s., Class 9, PG\nII!\" or \"NA3082, Hazardous waste, liquid, n.o.s., Class 9, PG III\"?\nA3. The answer is yes, the exception is limited to these two entries. Wastes offered\nunder these entries meet the criteria for inclusion in Class 9 because they are hazardous\nsubstances that equal or exceed the reportable quantity (RQ) listed in Appendix A to\n§172.101 that are not listed by name in the HMT and do not meet the definition of any\nhazard class 1 through 8. In accordance with § 172.203(c) for a material that is designated\nas a hazardous waste by EPA, and is also a hazardous substance, the waste code (e.g.,\nD001), if appropriate, may be used to identify the hazardous substance.\nQ4. Is the exception from the requirement to include a technical name in association with\nthe basic description on a shipping paper prescribed in § 172.203(k)(2)(i) limited only to\nClass 9 materials?\nA4. See A3.\nQ5. Is the exception from the requirement to include a technical name in association with\nthe basic description on a shipping paper prescribed in § 172.203(k)(2)(i) limited only to\nhazardous materials that are also hazardous substances?\nA5. The answer is yes. See A3.\nQ6. Is a hazardous material that is shipped using a generic proper shipping name, which\nis also a hazardous substance, subject to the additional description requirements in\n§ 172.203 (c) or § 172.203 (k); or would the requirements of both apply?\nA6.\nThe requirements in both § 172.203(c) and § 172.203(k) would apply.\nQ7.\nIs the following example an appropriate shipping description?\nRQ, UN1993, Waste Flammable Liquids, n.o.s., (isopropanol, xylenes), 3, PG II\n(D001)\n-Where \"isopropanol\" and \"xylenes\" are chemical constituents that make the\nmaterial flammable and the material is also a hazardous substance because it exceeds the\nRO for the DOOI waste code.\nA7.\nYes, this is an appropriate description for the scenario described.\n\n<<<PAGE 3>>>\n\nI trust this information is helpful. If you have further questions, please do not hesitate to\ncontact this office.\nSincerely,\nDeane A. Rinl\nDuane Pfund\nInternational Standards Coordinator\nStandards and Rulemaking Division\n\n<<<PAGE 4>>>\n\nWener\n8/72.203\nPapers\nDodd, Alice (PHMSA)\nбретоя\nFrom:\nSent:\nGeller, Shelby CTR (PHMSA)\nTo:\nThursday, June 04, 2015 3:58 PM\nHazmat Interps\nSubject:\nFW: Request for Written Letter of Interpretation\nAttachments:\nPHMSA RFI 20150614 EPA Waste Numbers vs Technical Names.pdf; 010020 - EPA\nWaste Numbers for Haz Substance.pdf; 990096 - EPA Waste Numbers as Technical\nNames.pdf\nHi Shante and Alice,\nPlease forward this for a formal letter of interpretation. Mr. Kucharski spoke with Adam Lucas in the HMIC.\nThanks,\nShelby\nFrom: Brian Kucharski [mailto:Brian.Kucharski@usecology.com]\nSent: Thursday, June 04, 2015 9:55 AM\nTo: INFOCNTR (PHMSA)\nSubject: Request for Written Letter of Interpretation\nHello,\nAttached is a request for written interpretation as well as two supporting documents.\nThank you,\nBrian Kucharski\nbrian.kucharski@usecology.com\n:: :\nUs ecology\nUSecology.com\n\n<<<PAGE 5>>>\n\nO US ecology\n17440 College Parkway, Suite 300, Livonia, MI 48152\n: 734.521.8000 : 734.521.8040\nJune 4th, 2015\nU.S. Department of Transportation\nPHMSA Office of Hazardous Materials Standards\nAttn: PHH-10\nEast Building\n1200 New Jersey Ave, SE\nWashington D.C. 20590\nRE: Request for Written Interpretation Regarding Description of Hazardous Wastes\nTo whom it may concern,\nI am requesting written interpretation regarding the basic description of hazardous\nmaterials which are also hazardous wastes (as defined in 49 CFR 171.8). A specific\nbackground scenario is provided as well as a series of questions. During research\non the topic of including EPA waste numbers in the DOT basic description of a\nhazardous material, two previous letters of interpretation (99-0096 and 01-0020)\nwere identified (attached) that provided some clarification. During internal\ndiscussion it was determined that additional interpretation is needed in order to\nfully clarify the details of this issue.\nBackground:\nUnder EPA regulation, consumer products that are damaged, returned or spilled\nand can not be used for their intended purpose become solid waste. In many\ninstances these products will exhibit characteristics of hazardous waste and must\nbe properly packaged and shipped for final disposal. Consumer products made of\nmany different ingredients can exhibit the same characteristics of hazardous waste;\nie. ignitable waste can include chemicals such as acetone, xylene, mineral spirits;\nkerosene and ethyl alcohol to name a few. These products would have an EPA\nHazardous Waste Number of D001. When shipping these hazardous\nmaterials/hazardous wastes using a generic proper shipping name, DOT requires\nthat technical name(s) be provided as additional information per 49 CFR\n173.203(k). The following questions seek to clarify the requirements and\nexceptions for provision of technical names and the ability to utilize the EPA's\nHazardous Waste Number as additional information.\nUnequaled\nservice. Solutions you con trust.\nUSecology.com\n\n<<<PAGE 6>>>\n\nQ1 - Does the definition of a \"technical name\" in 49 CFR 171.8 include the EPA's\nhazardous waste numbers (sometimes referred to as waste codes)? Example:\nUN1993, Waste Flammable Liquids, n.o.s., (D001), 3, PGII\nWhere \"D001\" is the technical name\n[For questions 2-4, It appears that 49 CFR 172.203 (k)(2) (i) provides relief from the\nrequirement to further describe a generic proper shipping name using one or more\ntechnical names. The next three questions are specific to the applicability of this\nrelief:]\nQ2 - Is this relief limited only to shipments using the \"Hazardous Waste, solid,\nn.o.s.\" or \"Hazardous Waste, liquid, n.o.s.\" proper shipping name?\nQ3 - Is this relief limited only to class 9 hazardous materials?\nsubstances?\nQ4 - Is this relief limited to only hazardous materials that are also hazardous\n[The next question is specific to how to determine additional information required\nby 49 CFR 172.203:]\nQ5 - Is a hazardous material that is shipped using a generic proper shipping name,\nwhich is also a hazardous substance, subject to the additional description\nrequirements of only either 49 CFR 172.203(c) or 49 CFR 172.203(k); or would\nboth need to be complied with? Example:\nRQ, UN1993, Waste Flammable Liquids, n.o.s., (isopropanol, xylenes), 3, PGII\n(D001)\nWhere \"isopropanol\" and \"xylenes\" are chemical constituents that make the\nhazardous material flammable, and the hazardous material is a hazardous\nsubstance because it exceeds the RQ threshold for the D001 waste number.\nSincerely,\nBrian Kucharski\nDOT Compliance Manager\nUS Ecology - Regional Office\n17440 College Parkway, Suite 300\nLivonia, MI 48152\nAttachments (2)\nUnequaled service, Solutions you car truer.\nUSecology.com\n\n<<<PAGE 7>>>\n\nof Transportation\nU.S. Department\n400 Seventh St., S.W.\nSpecial Programs\nResearch and\nWashington, D.C. 20590\nAdministration\nJUN 2 0 2001.\nMr. David M. Kolan\nEnvironmental Scientist\nReference No.: 01-0020\nOrg. G-1244, M/C 7A-WH\nThe Boeing Company\nP. O. Box 3707\nSeattle, WA 98124-2207\nDear Mr. Kolan:\nThis is in response to your inquiry concerning the placement of the waste code in the shipping\ndescription shown on a shipping paper under 49 CFR 172.203. Specifically, you ask whether the\nwaste code may precede the shipping name, for example, as follows:\nRQ (D001), Waste Flammable Liquid, n.o.s. (methyl ethyl ketone, toluene), 3, UN 1993, PG III.\nThe answer is no. Under § 172.203(c)(1), the waste code number must be identified in\nparentheses \"in association with\" the basic description when the waste code is used to identify\nthe hazardous substance. The term, \"in association with,\" means that the component may follow\nthe basic description of the hazardous material in any reasonable format, provided it is clearly\nidentification number, and packing group is required by § 172.202(b) to be entered in sequence,\npart of the entry. The basic description consisting of the proper shipping name, hazard class,\nwith authorized exceptions. This position is supported by the preamble discussion of the final\nrule that adopted this terminology into the HMR (copy enclosed). Among the authorized\nexceptions are entering the letters \"RQ\" before or after the basic description as authorized by\n§ 172.203(c)(2)) and entering the technical name or chemical name between the proper shipping\nname and hazard class as authorized by § 172.202(d).\nI hope this satisfies your request. Please contact us if we can be of further assistance.\nSincerely,\nHothe z mitheel\nHattie L. Mitchell\nChief, Regulatory Review and Reinvention\nOffice of Hazardous Materials Standards\nEnclosure\ncc: Ms. Linda Schinke, Safety Manager\n•formia. Vehicle Division\n172,203\n010020\n\n<<<PAGE 8>>>\n\nEnclosure\nFederal Register / Vol. 45, No. 101 / Thursday, May 22, 1980 / Rules and Regulations\n34581\nn.o.s. be revised to agree with those\nprovided for the same entries in\nhave been revised to agree with those in\nstowage of these materials as specified\n§ 172.101. Since the IMCO Code allows\nthe IMCO Code.\nmaterial appearing on the shipping\nclass and identification number for a\nrevised as proposed in Dockets HM-\nSection 172.200. Section 172.200(b) is\npaper must be taken either entirely from\nby the competent authority, MTB agrees\nappropriate and has revised the stowage\nthat the proposed change is entirely\n145A and HM-1458, to remove the ORM\nhas amended § 172.400 to insure that the\n§ 172.101 or entirely from § 172.102, and\nreguirements when a material being\nexceptions to the shipping paper\nproper shipping name market on the\npackage labeling is consistent with the\nlocation designations accordingly.\nidentification numbers indicated for the\nAn obiection was raised to the\noffered or transported is a hazardous\nwaste or a hazardous substance. The\npackage.\nSilicofluorides, solid, n.o.s, on the basis\nentries Sodium fluoride, solution and\nsimplified in the Einal rule, without\nwording of the proposal has been\ncommenters for insuring that some\nVarious methods were suggested by\nthat neither the IMCO Code nor the UN\nORM-E materials has been deleted\nchanged effect. The proposed entry for\nindication is included in the shipping\n§ 172.102 is being utilized. MIB believes\npaper description when an entry from\nidentification number for those entries.\nRecommendations specifies an\nsince the exception proposed in the\nhowever, adopted by the UN Committee\nNumbers for these materials were,\nNotice is unnecessary under the final\nprovided, since the class of a material is\nthat such an indication is already\nat its Tenth Session (December 1978)\n(a)[1](iii), and (a](4)(1) of § 172.201 are\nSection 172.201. Paragraphs (a)(1)(ti).\nalways expressed numerically in\ntherefore, would have to be indicated in\nColumn (3] of the Optional Table and,\nthe UN Recommendations, The numbers\nand will appear in the next edition of\nrevised by MTB to accommodate the\ncontained in the proposal have,\nrequires the identification number\nrevision to § 172,202(a)(3) which\npapers. This means that a numerical\nthe same manner on the shipping\ncommenter suggested that the letter \"N\"\ntherefore, been retained. The same\npreceded by \"UN\" or \"NA\", as\nindication of the class on the shipping\nanhydrous and solutions containing less\nbe inserted before the entry \"Hydrazine,\nelement of the basic description, as\neppropriate, to be entered as the third\npapers will serve as a direct indication\nis offered is taken from § 172.102.\nthat the entry under which the material\nthan 36% water by weight\" because the\nproposed in Docket HM-126A. Also,\nand to pravide an example since the rule\nParagraph (b) is revised for clarity\nhydrazine solutions in the Optional\nclass and labels provided for these\n(a)(1)(iii) to authorize the entry of \"RQ\"\nMTB added a provision to paragraph\nprevious example, Corrosive liquid,\nchange to paragraph (a)(2)(ii) made the\nTable disagree with the DOT class aud\nin the \"HM\" column in place of the \"X\"\nhe considered the DOT classification to -\nlabels for thase materials and because\nhazardous substance. This waa\nto identify the entry as representing a\nparagraph (b) now indicates, that the\nn.o.s., incorrect. It should be noted, as\nbe adequate. MTB believes that use of\nrecommended by several commenters.\nbasic description now consists of three\nsolutions will not result in a derogation\nthe IMCO class and labels for these\nand MTB concurs. As proposed in\nhazard class, and the identification\nelements: the proper shipping name, the\namended to allow the optional insertion\nDocket HM-171, paragraph (a)(4)(1) is\nnumber. However, technical names may\nof the letter \"N\" before entries solely\nof safety in transportation. The insertion\nof the entries \"IMCO\" or \"IMCO Class\"\nproper shipping name. These\nbe required to be entered after the\nin the hazardous materials description\nIMCO may be different from those\nbecause the class and label(s) under\non the shipping papers. MTB believes\nrequirements were proposed in Dockets\ninclude these entries to clarify the fact\nthat certain shippers may desire to\nHM-126A and HM-145B.\nprovided in § 172.101 is contrary to the\nrequired to be made \"in association\nSome shipping paper entries are.\nOptional Table. The suggestion has,\npurpose and intent of adopting the\noffered under the IMCO hazard class,\nthat a hazardous material is being\nwith\" the basic description. The term \"in\ntherefore, not been incorporated into the\nparticularly when this hazard class\nadditional entry may follow the\nassociation with\" means that the\nOptional Table.\nmaterial in §172.101. A proposal that\ndiffers from that provided for the\nto add certain shipping descriptions to\nA number of requests were received\ncomplete description for a hazardous\nimmediately before the proper shipping\nthe entry \"IMCO\" be allowed to appear\nlong as it is clearly part of the entry.\nmaterial in any reasonable format, as\nthe Optional Table which appear as\nare also acceptable alternate\nproper shipping names in § 172.101 and\nMTB's belief that the proper shipping\nname has not been adopted since it is\ndescription in a prescribed sequence,\nThe requirement to enter the basic\nname should appear first in the basic\nnot preclude the use of a shipping paper\nwith certain exceptions specified, does\ndescriptions for the materials in the\nbeen included in Roman type in the\nIMCO Code. Such descriptions have\nhazardous materials description.\n{a)(2) are revised by MTB to clarify the\nSection 172.202. Paragraphs (a)[1) and\nbasic description sequence must be\nformat with columns. However, the\nOptional Table with a cross reference to\nuptional, Also, paragraph (a)(2) is\nfact that the entries in § 172.102 are\nmaintained, with authorized exceptions.\ndescription for the material in the IMCO\nthe entry which appears as the primary\naddition of the identification number to\nParagraph (b] is revised to show the\naddition to the Optional Table of certain\nCode. Other comments requested the\nrevised to reduce some of the shipping\nthe Optional Table are used for\npaper entries. Whenever entries from\nthe basic description.\nshipping descriptions which appear in\nMTB does not consider it appropriate to\n§ 172.101 bul not in the IMCO Code.\ndomestic shipments. § 171.102 applies. A\nconcern that the proposal would allow\nnumber of commenters expressed\npapers in order to assist water carriers\nthe indication of flashpoint on shipping\nrecognized by IMCO for international\nadd such entries because they are not\nshipping descriptions, classification and\nunrestricted mixing of DOT and IMCO\nbelieves that, in general, the indication\nin planning vessel stowage. MTB\nlabeling which could result in confusion\nof the appropriate IMCO division\ndiscrepancies between the entries for\nOne commenter noted several\nand suggested that this paragraph be\nnumber for flammable liquids\nmixing, MTB agrees with these\namended to prevent such unrestricted\nsufficiently specifies flashpoint for\nOptional Table and those in the IMCO\n\"Fishmeal\" or \"Fishscrap\" in the\nrelatively few instances where the\nstowage purposes, and that the\nCode. The entries in the Optional Table\ncomments and has amended § 172.202 to\nrequire that the proper shipping name\nstowage of hazardous materials of other\nclasses is dependent on flashpoint\n\n<<<PAGE 9>>>\n\nThe Boeing Company\nSeattle, WA 98124-2207\nP.O. Box 3707\n• Corbin\n8172.203(C)\nJanuary 17, 2001\nShipping Papers\nG-1244-DMK-003\nMr. Edward Mazzullo, Director,\nOffice of Hazardous Materials Standards (DHM-10),\nResearch and Special Programs Administration,\nRoom 8422,\nBOEING\n400 Seventh Street, SW.,\nWashington, DC 20590-0001\nDear Mr. Mazzullo:\nSubject:\nInterpretation of 49 CFR 172.203(c) et al.\nShipping Papers\nI am writing to inquire about the appropriate interpretation of the rule noted above, as\nit relates to shipping papers for hazardous wastes. I inquire as a result of a Uniforn\nDriver/Vehicle Inspection Report, a copy of which is enclosed with this letter. We\nfeel that there are at least two ways to indicate the RQ and hazardous substance\ninformation on a manifest and packaging label. One way to indicate RQ information\nwith the basic description is as follows:\nWaste Flammable Liquid, n.o.s., (methyl ethyl ketone, toluene),\n3, UN1993, PG II, RQ (D001)\nSpecifically, I would like to know whether it also complies with U.S. Department of\nTransportation (DOT) rules if one identifies a hazardous substance on a manifest as\nfollows:\nRQ (D001), Waste Flammable Liquid, n.o.s., (methyl ethyl ketone, toluene),\n3, UN1993, PG III.\nbut in front of the basic description?\nThat is, is it acceptable to place a waste code in a parenthetical after the letters \"RO\"\nWe have interpreted 49 CFR 172.203(c)(2), which requires placing the letters \"RQ\"\neither before or after the basic description, to allow the parenthetical informatios\n(naming the relevant hazardous substance or applicable RCRA waste code) to be\nidentified as a unit with the letters \"RO.\" This sequence, of course, makes common\nsense, in that it clearly identifies the substance triggering the RQ designation. It is\nalso consistent with 49 CFR 203(c)(1), which requires the name of the hazardous\nsubstance, or a waste code, to be entered in parentheses in association with the basic\ndescription.\n\n<<<PAGE 10>>>\n\nIt is also the only way to achieve consistency between the shipping paper sequence\nand the non-bulk package labelling requirements in 49 CFR 172.324. This latter\nprovision requires the letters RQ and the name of the hazardous substance, or a waste\ncode, to be marked in association with the proper shipping name on the package.\nSince 49 CFR 172.202 requires that the proper shipping name be the first part of the\nbasic description and 49 CFR 203(c)(2) requires placing the letters \"RQ\" either\nbefore or after the basic description, then the only way to have the RQ and the name\nof the hazardous substance, or a waste code, marked in association with the proper\nshipping name is to put them both up front.\nBOLING\nOur interpretation also appears to be consistent with 49 CFR 172.202(b), which\nprohibits changing the sequence of the basic description or interspersing additional\nnce it appears that the letters \"RO\" and the name of the hazardous substance, or\nformation \"except as provided in this subpart\" (i.e., Subpart C, Shipping Papers\nwaste code, should be associated with the proper shipping name.\ncontact me at (425) 865-6521. Thank you for your assistance.\nWe would appreciate your guidance on this question. Please do not hesitate to\nSincerely,\nDavid M. Kolan\nEnvironmental Scientist\nOrg. G-1244, M/C 7A-WH\nPhone: 425-865-6521\nE-mail: david.m.kolan@boeing.com\nCo:\nMs. Linda Schinke, Safety Manager\nCommercial Vehicle Division,\nWashington State Patrol\nPOLARA\n2\n\n<<<PAGE 11>>>\n\nof Transportation\nU.S. Department\n400 Seventh Street, S.W\nNashington, D.C\n20590\nSpecial Programs\nResearch and\nAdministration\nAUG -6 1999\nMr. Paul Bomgardner\nRef. No.\n99-0096\nDirector, Hazardous Materials Policy\nAmerican Trucking Associations\n2200 Mill Road\nAlexandria, VA\n22314-4677\nDear Mr. Bomgardner:\nThis is in response\nthe placement of an U.S. Environmental Protection Agency (EPA)\nto your letter dated April 8, 1999, regarding\nwaste code in shipping descriptions for hazardous wastes.\nbetween the\nSpecifically, you ask if a materials EPA waste code can be placed\nshipping name and hazard class.\nSection 172.202 (d) authorizes the placement of technical and\nchemical group names between\nthe proper shipping name and hazard\nclass.\nIt is the opinion of this Office, that the hazardous\nwaste\nshipping papers, between the proper shipping name and hazard\nclass.\nwaste, liquid or solid, n.o.s.\", an EPA hazardous waste code\ncannot be used to satisfy the requirement to place the technical\nname of the hazardous material in association with the basic\ndescription. (See $ 172.203 (k)).\nI hope this satisfies your request.\nsincerely,\nomar I. All.\nThomas G. Allan\nActing\nDirector\nOffice of Hazardous Materials\nStandards\n172.202\n990096\n• 3\"\n-i-\n\n<<<PAGE 12>>>\n\nAMERICAN TRUCKING ASSOCIATIONS\nATAR\n2200 Mill Road * Alexardria, VA * 22314-4677\nGale\nDriving Trucking's Success\n§172.202\nSafety Policy\nApril 8, 1999\n990096\nMr. Delmar Billings\nOffice of Hazardous Materials Standards\nResearch and Special Programs Administration\nU. S. Department of Transportation\n400 Seventh Street, SW\nWashington, DC 20590\nRe:\nRequest for clarification regarding placement of an alpha-numeric waste code in shipping\npaper descriptions for hazardous wastes.\nDel\nDear My Billings:\nLately, transporters have been running into difficulty in several states regarding the placement of\nthe alpha-numeric waste code in the description of a hazardous waste on hazardous waste\nmanifests. Carriers are being cited for placing the waste code, in lieu of the complete waste\nstream information, between the proper shipping name and hazard class. States have cited as\nbasic description.\ntheir reasoning that the waste code is not a technical name, and therefore must be placed after the\nWe disagree. Section 172.203(c)(1) permits the use of the waste code in lieu of the technical\nname for hazardous wastes. Section 172.202(d) states that technical and chemical group names\nthe basic description. Since section 172.203(c)(1) permits the use of the waste code in lieu of the\nmay be entered in parentheses between the proper shipping name and hazard class or following\ntechnical name, placement of the waste code should be governed by the provisions of section\n172.202(d), and be allowed to be placed, in parentheses, between the proper shipping name and\nhazard class. Additionally, because the alpha-numeric waste code specifically identifies the\nwaste stream it should be considered to be a technical name by definition. This is affirmed by the\nfact that section 172.203(c)(1) permits its use in lieu of the full alpha technical name.\nsituation in our favor. The waste code should be allowed to be placed, in parentheses either\nWe believe that Research and Special Programs Administration (RSPA) should rectify this\nbetween the proper shipping name and hazard class or following the basic description.\nThank you for your assistance in this matter. If you have any questions regarding this request,\nplease contact me on 703-838-1849.\nDel Billings\ntalent w/ Pacel.\nten: ?\nwaste n.o.5\nPaul Bomgardner\nDirector, Hazardous Materials Policy\nAnswer letter\nHAT.\nstr\n(703) 838-1847 * Fax: (703) 683-1934","truncated":false,"body_characters":25645}