Interpretation Response #01-0248 ([Fluor Hanford Waste Services] [Mr. Paul W. Martin])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date: 01/03/2002

Company Name: Fluor Hanford Waste Services

Individual Name: Mr. Paul W. Martin

Location State: WA Country: US

View the Interpretation Document

Response text:

January 3, 2002

Mr. Paul W. Martin                            Reference No. 01-0248
Fluor Hanford Waste Services/
Waste Management Project
P.O. Box 700
T3-04 MO-279, 200 West Area
Richland, WA 99352-0700

Dear Mr. Martin:

This responds to your facsimiles and telephone conversations with staff members of this office on the correct classification under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) of high-pressure, sodium-vapor lamps being transported for disposal.  You state that these lamps will be transported in bulk, and that many will be crushed as they are packaged.  I apologize for the delay in responding and any inconvenience it may have caused.

The two material safety data sheets (MSDS) you provided describe one lamp as containing the following materials:

The second lamp contains the following materials:

Neither MODS describes the lamps as meeting an HMR hazard class or provides a protocol for transporting crushed lamps in bulk.  One MODS states the sodium in the lamps may produce heat when in contact with water, but the amount of sodium in a single lamp is so small it generally presents no hazard.  Both MODS's prescribe methods for handling mercury vapor, lead dust, and other chemicals and materials the lamps contain.

Under § 173.22, it is the shipper's responsibility to determine the hazard class for a hazardous material.  This office does not perform that function.  However, based on the information you provided, we agree with your determination that a bulk package filled with the crushed lamps would contain a sufficient amount of hazardous material to meet the definition of a Division 4.3 material in § 173.124. You should also determine if the package contains a sufficient amount of lead, mercury, or sodium to meet the definition in § 171.8 for a hazardous substance.  Further, we agree with your determination that an uncrushed lamp, provided it is not packaged with or contaminated by material from a crushed lamp, is not regulated as a hazardous material under the HMR.

I hope this information is helpful.

Sincerely,

John A. Gale
Transportation Regulations Specialist
Office of  Hazardous Materials Standards

173.22

Regulation Sections