{"operation":"document","citation":"99-0012","title":"Safety-Kleen Corporation — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1999-09-07","effective_on":null,"summary":"99-0012 response to Safety-Kleen Corporation concerning 172.203.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-99-0012.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-99-0012.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-99-0012","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/1999/990012.pdf","body":"<<<PAGE 1>>>\n\nUS. Department\nof Transportation\n400 Seventh Street. S.W.\nSpecial Programs\nResearch and\nWashington, D.C.\n20590\nSEP 14517 1999\nAdministration\nMr. Jerry Davis\nSafety-Kieen Corporation\nRef. No. 99-0012\n1301 Gervais Street, Suite 300\nColumbia, South Carolina 29201\nDear Mr. Davis:\nThis is in response to your letter asking if it is acceptable for Safety-Kleen Corporation to include the\ntechnical names of several different waste mixtures and solutions, having the same proper shipping\nname, hazard class, and identification number, in block \"15\" of a Uniform Hazardous Waste Manifest\n(UHWM). For example, several different wastes from several different generators are described on\nthe UHWM using a generic shipping name, such as \"Waste flammable liquid, n.o.s., 3, UN 1993, PG\nII.\" The technical names for these different wastes are entered in block \"15\" of the UHWM. I\napologize for the delay in responding and hope it has not caused any inconvenience.\nUnder the HMR, both the basic description and any additional descriptive information required to be\nassociated with the basic description under the provisions of 49 CFR 172.203, should appear in block\n\"11\" of the UHWM. Any additional information required by 49 CFR 172.203 that is required to be\nplaced \"in association with the basic description\" may follow the basic description in any reasonable\nformat, provided it is clearly part of that specific entry. Although it is preferable to use block \"11,\" in\nthose instances where only one hazardous material description is entered on the UHWM, block \"J\" in\naddition to block \"11\" may be used to include the technical name entries.\nThus, no exemption is required when only one basic description is used to describe several generators'\nhazardous wastes on the UHWM, provided the packages contain hazardous wastes with the same\nproper shipping name, hazard class, identification number, and packing group, and block \"J\" is used to\nidentify the technical names of the constituents of the mixtures or solutions.\nI hope this satisfies your inquiry. If we can be of further assistance, please contact us\nSincerely,\nJun Billi\nDelmer F. Billings\nChief, Standards Development\nOffice of Hazardous Materials Standards\n172.283\n990012\n\n<<<PAGE 2>>>\n\nEngrove\nBeetre\n§172.203\nsafety-kleen®\n99-0012\nVIA FACSIMILE TRANSMISSION AND U.S. MAIL\nJanuary 5, 1999\nDelmer Billings\nChief, Standards Development\nResearch and Special Programs Administration\nU.S. Department of Transportation\n400 Seventh Street, Southwest\nWashington, DC 20590-0001\nSUBJECT: REQUEST FOR INTERPRETATION\nDear Mr. Billings:\nSafety-Kleen Corp. ('S-K'\") is requesting an interpretation of 49 CFR 172.203 (k)(1)\nanaterial on the shipping paper regaires a entri highnical malist in 49 dor.\n172.203 (k)(3) to describe a hazardous material. When describing a mixture or solution\ntechnical names (in parentheses) of at least two components most predominately\nof two or more hazardous materials, 49 CFR 172.203 (k)(2) requires us to enter the\ncontributing to the hazards.\nNumerous generic shipping descriptions are used to describe various mixtures. These\nmixtures frequently have the same dangers and hazards, even though they may be\nshipping descriptions entered on the shipping paper, the number of shipping papers\nrequired for transportation, and the number of employees required to manage the\nS-K wishes to combine and include the technical names associated with generic\nshipping descriptions in one location on the shipping paper, as long as the proper\nshipping name, hazard class, and identification number are the same. This request is\ndue to the financial burden we are presently experiencing as a result of managing an\nenormous number of shipping papers. For example, nearly 7,500 shipping papers are\nreceived at our facilities on a daily basis; another 3,500 are prepared daily by S-K\npersonnel for outgoing shipments.\nSAFETY-KLEEN CORP.\n1301 GERVAIS STREET, SUITE 300\nCOLUMBIA, SOUTH CAROLINA 29201\n803/933-6434\nFAX 803/933-6435\n\n<<<PAGE 3>>>\n\nPage 2/Letter to Delmer Billings/January 5, 1999\nAttached is a scenario that describes what we are presently doing and what we would\nlike to do going forward. Our question is summarized as follows: Will the Research\ninclude the technical names associated with generic shipping descriptions in on\nnd Special Programs Administration (\"RSPA\") grant us permission to combine an\nlocation on the shipping paper, as long as the proper shipping name, hazard class, and\nidentification number are the same?\nWe previously submitted our request as an application for an exemption to the\nExemptions and Approvals Department. However, upon review, Helen Engrum and\nAnn Mazzullo said that our request should be processed as an interpretation rather than\nan exemption. Your immediate response is greatly appreciated.\nPlease feel free to contact me at (803) 933-6434 should you have any questions or need\nadditional information.\nSincerely,\nSAFETY-KLEEN CORP.\nBy:\nJerry d. Hain\nerry D. Davi\nDirector, Corporate Transportation Compliance","truncated":false,"body_characters":5029}