Interpretation Response #99-0230 ([CleanHarbors Environmental Services, Inc.] [Mr. Peter W. Egan])

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

Interpretation Response Details

Response Publish Date: 04/05/2000

Company Name: CleanHarbors Environmental Services, Inc.

Individual Name: Mr. Peter W. Egan

Location State: MA Country: US

View the Interpretation Document

Response text:

April 5, 2000

Mr. Peter W. Egan                       Ref.  No. 99-0230
Director of Regulatory Affairs
CleanHarbors Environmental Services, Inc.
1501 Washington Street
Braintree, MA 02185

Dear Mr. Egan:

This responds to your letter of August 13, 1999, concerning requirements for shipping a hazardous waste mixture under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you ask about shipment of a waste corrosive liquid that emits a very low level of hydrocyanic acid (HCN).

You describe the waste material, called Alodine, as a mixture composed of 99% water, 0.5% chromic acid, 0.5% potassium ferricyanide, and less than 0.1% nitric acid.  You have determined that waste Alodine is properly classed and described as RQ Waste Corrosive Liquid, Acidic, Inorganic, n.o.s. (Chromic Acid), 8, UN 3264, PG II.  You state that the mixture does not meet the definition of a Division 6.1 (poisonous) material.  However, over time, Alodine emits very small mounts of HCN, which can accumulate in the headspace of the 55 gallon drums or bulk packagings in which it is transported.  You ask if there is an upper limit on the amount of HCN that may accumulate in the headspace of a non-bulk or bulk packaging above which the shipment of waste Alodine would be prohibited under the HMR.

Under § 173.22 of the HMR, it is the shipper's responsibility to determine the appropriate class for a hazardous material.  Such determinations are not required to be verified by this office.  However, based on the information you have provided, it does not appear that the HCN emitted by waste Alodine will accumulate in amounts sufficient to present a safety hazard during transportation.  Thus, waste Alodine may be offered for transportation as a Class 8 material pursuant to the HMR.

I hope this information is helpful.  If you have further questions, please do not hesitate to contact this office.

Sincerely,

Thomas G. Allan
Senior Transportation Regulations Specialist
Office of Hazardous Materials Standards

173.21

Regulation Sections