Safety-Kleen Corporation — Hazardous Materials Safety Interpretation

Page 1US. Department of Transportation 400 Seventh Street. S.W. Special Programs Research and Washington, D.C. 20590 SEP 14517 1999 Administration Mr. Jerry Davis Safety-Kieen Corporation Ref. No. 99-0012 1301 Gervais Street, Suite 300 Columbia, South Carolina 29201 Dear Mr. Davis: This is in response to your letter asking if it is acceptable for Safety-Kleen Corporation to include the technical names of several different waste mixtures and solutions, having the same proper shipping name, hazard class, and identification number, in block "15" of a Uniform Hazardous Waste Manifest (UHWM). For example, several different wastes from several different generators are described on the UHWM using a generic shipping name, such as "Waste flammable liquid, n.o.s., 3, UN 1993, PG II." The technical names for these different wastes are entered in block "15" of the UHWM. I apologize for the delay in responding and hope it has not caused any inconvenience. Under the HMR, both the basic description and any additional descriptive information required to be associated with the basic description under the provisions of 49 CFR 172.203, should appear in block "11" of the UHWM. Any additional information required by 49 CFR 172.203 that is required to be placed "in association with the basic description" may follow the basic description in any reasonable format, provided it is clearly part of that specific entry. Although it is preferable to use block "11," in those instances where only one hazardous material description is entered on the UHWM, block "J" in addition to block "11" may be used to include the technical name entries. Thus, no exemption is required when only one basic description is used to describe several generators' hazardous wastes on the UHWM, provided the packages contain hazardous wastes with the same proper shipping name, hazard class, identification number, and packing group, and block "J" is used to identify the technical names of the constituents of the mixtures or solutions. I hope this satisfies your inquiry. If we can be of further assistance, please contact us Sincerely, Jun Billi Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards 172.283 990012#

Page 2Engrove Beetre §172.203 safety-kleen® 99-0012 VIA FACSIMILE TRANSMISSION AND U.S. MAIL January 5, 1999 Delmer Billings Chief, Standards Development Research and Special Programs Administration U.S. Department of Transportation 400 Seventh Street, Southwest Washington, DC 20590-0001 SUBJECT: REQUEST FOR INTERPRETATION Dear Mr. Billings: Safety-Kleen Corp. ('S-K'") is requesting an interpretation of 49 CFR 172.203 (k)(1) anaterial on the shipping paper regaires a entri highnical malist in 49 dor. 172.203 (k)(3) to describe a hazardous material. When describing a mixture or solution technical names (in parentheses) of at least two components most predominately of two or more hazardous materials, 49 CFR 172.203 (k)(2) requires us to enter the contributing to the hazards. Numerous generic shipping descriptions are used to describe various mixtures. These mixtures frequently have the same dangers and hazards, even though they may be shipping descriptions entered on the shipping paper, the number of shipping papers required for transportation, and the number of employees required to manage the S-K wishes to combine and include the technical names associated with generic shipping descriptions in one location on the shipping paper, as long as the proper shipping name, hazard class, and identification number are the same. This request is due to the financial burden we are presently experiencing as a result of managing an enormous number of shipping papers. For example, nearly 7,500 shipping papers are received at our facilities on a daily basis; another 3,500 are prepared daily by S-K personnel for outgoing shipments. SAFETY-KLEEN CORP. 1301 GERVAIS STREET, SUITE 300 COLUMBIA, SOUTH CAROLINA 29201 803/933-6434 FAX 803/933-6435#

Page 3Page 2/Letter to Delmer Billings/January 5, 1999 Attached is a scenario that describes what we are presently doing and what we would like to do going forward. Our question is summarized as follows: Will the Research include the technical names associated with generic shipping descriptions in on nd Special Programs Administration ("RSPA") grant us permission to combine an location on the shipping paper, as long as the proper shipping name, hazard class, and identification number are the same? We previously submitted our request as an application for an exemption to the Exemptions and Approvals Department. However, upon review, Helen Engrum and Ann Mazzullo said that our request should be processed as an interpretation rather than an exemption. Your immediate response is greatly appreciated. Please feel free to contact me at (803) 933-6434 should you have any questions or need additional information. Sincerely, SAFETY-KLEEN CORP. By: Jerry d. Hain erry D. Davi Director, Corporate Transportation Compliance#