Interpretation Response #99-0310 ([The Texas A&M University System] [Mr. Jeff R. Bowman])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: The Texas A&M University System
Individual Name: Mr. Jeff R. Bowman
Location State: TX Country: US
View the Interpretation Document
Response text:
March 17, 2000
Mr. Jeff R. Bowman Ref No. 99-0310
The Texas A&M University System
Public Service Training Division
600 Hemis Fair Plaza Way, Building 227
San Antonio, Texas 78205-3223
Dear Mr. Bowman:
This is in response to your letter regarding the requirements for inclusion of a technical name(s) for a hazardous waste described by generic or n.o.s. description under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).
You stated that a common practice of emergency response contractors is to perform a hazard characterization ("HA.ZCAT") field test as a method to determine the hazard category for unknown hazardous wastes from an emergency response cleanup, and selection of a generic or n.o.s. description to identify the waste materials. Disposal sites often accept these unknown wastes identified under the HAZCAT field test method. Once the waste is received at the disposal site, additional analysis, if required, may then be performed.
You asked how the technical name should be shown for generic or n.o.s. proper shipping names (PSNs), other than "Hazardous waste liquid or solid, n.o.s.". Can it be assumed that since additional testing may be performed by the disposal site, these generic PSNs are excepted from the technical name(s) requirement as specified in § 172.203(k)(2)(ii)?
The answer is no. The technical name exception in § 172.203(k)(2)(ii) only applies to a hazardous material for which the hazard class is to be determined by testing under the criteria of § 172.1 01(c)(I 1). This does not include analysis performed at a disposal site.
I hope this satisfies your inquiry. If we can be of further assistance, please contact us.
Sincerely,
Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards
172.203
Regulation Sections
| Section | Subject |
|---|---|
| 172.203 | Additional description requirements |