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Interpretation Response #00-0014 ([Waste Technology Services Inc.] [Mr. David J. Passuite])

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

Interpretation Response Details

Response Publish Date:

Company Name: Waste Technology Services Inc.

Individual Name: Mr. David J. Passuite

Location State: CT Country: US

View the Interpretation Document

Response text:

February 8, 2000

Mr. David J. Passuite                Ref. No. 00-0014
Waste Technology Services Inc.
6 Forest Park Drive
Farmington, CT 06032

Dear Mr. Passuite:

This is in response to your letter concerning the requirements for lab pack shipments under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you requested clarification on the marking requirements when a lab pack contains a material listed in the hazardous materials table (HMT) in § 172.101 with a plus (+) sign in column one (e.g., Benzaldehyde) and whether these materials may be lab packed with other hazardous materials.  You also ask about the proper method of describing this material on a uniform hazardous waste manifest and hazardous waste labels required by the Environmental Protection Agency (EPA).

The lab pack exception in §173.12(b) provides relief from specification packaging if packaged in accordance with the section and allows the shipper to use a generic name to represent compatible materials in the same hazard class in place of specific chemical names when packaged in the same outer packaging.  Since Benzaldehyde has a "+" sign in column one, that name is fixed and cannot be replaced with a generic shipping name.  In this case, the material may be packaged with the other compatible hazardous materials.  However, the specific shipping name must be marked on the outside packaging in addition to the generic description for the other hazardous materials in the lab pack and listed separately on the shipping paper.  Further requirements for lab packs are found in § 173.12(b).

Since the hazardous waste manifest serves as the shipping paper, the requirement to describe
Benzaldehyde separately applies when using a hazardous waste manifest.  Your question concerning the EPA requirement for hazardous waste labels would best be answered by the EPA.  You can contact the RCRA, EPCRA, and Superfund hotline at 1-800-424-9346.

I hope this satisfies your request.


Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.12 Exceptions for shipment of waste materials