Interpretation Response #13-0185 ([Veolia ES Technical Solutions, L.L.C.] [Ms. Jennifer Eberle])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Veolia ES Technical Solutions, L.L.C.
Individual Name: Ms. Jennifer Eberle
Location State: NJ Country: US
View the Interpretation Document
Response text:
February 18, 2014
Ms. Jennifer Eberle
Manager, Transportation Compliance
Veolia ES Technical Solutions, L.L.C.
1 Eden Lane
Flanders, NJ 07836
Ref. No. 13-0185
Dear Ms. Eberle:
This is in response to your September 5, 2013 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR 171-180) applicable to preparation of one element of a U.S. Environment Protection Agency (EPA) Uniform Hazardous Waste Manifest (UHWM) when used as an alternative to a shipping paper required by the HMR. Specifically, you ask whether a net or a gross mass, volume, or activity must be indicated in Block 10 of a UHWM for transportation by modes other than aircraft. You also state in your letter that if the answer is “yes,” then you are challenging the response in a previously issued interpretation letter, under Ref. No. 13-0052, that indicates otherwise.
The answer to your question is yes, except as otherwise provided in § 172.202(a)(5), a net or a gross mass, volume, or activity may be indicated on either a shipping paper or a EPA UHWM for transportation by modes other than aircraft. For transportation by aircraft, entries may only be indicated as the net sum of hazardous materials as prescribed in
§ 172.202(a)(6). Thank you for bringing this matter to our attention. We intend to correct our previous response as quickly as possible.
I trust this information is helpful. Please contact us if you require further assistance.
Sincerely,
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
172.202
Regulation Sections
| Section | Subject |
|---|---|
| 172.202 | Description of hazardous material on shipping papers |