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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #00-0021 ([Mr. Theron R. Brayman])

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

Interpretation Response Details

Response Publish Date:

Company Name:

Individual Name: Mr. Theron R. Brayman

Location State: MI Country: US

View the Interpretation Document

Response text:

April 21, 2000

Mr. Theron R. Brayman                 Ref.  No. 00-0021
Dow Corning
P.O. Box 995
Midland, MI 48686-0995

Dear Mr. Brayman:

This is in response to your letter dated January 18, 2000, requesting clarification on the proper shipping description for a lab pack containing materials with the same primary hazard class but different subsidiary hazard classes under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you ask whether materials with the same primary hazard class with different subsidiary hazard classes in a lab pack, may be described by a single generic shipping description that includes all the possible subsidiary hazard classes that may or may not be present in the outer packaging at the time of shipment.  For example, is  &quo;flammable liquid, toxic, corrosive, n.o.s." an acceptable description for a lab pack containing flammable liquids, some of which have toxic or corrosive subsidiary hazards?

A generic description from the § 172.101 table may be used in place of specific chemical names, when two or more chemically compatible waste materials in the same hazard class are packaged in the same outside packaging.  Chemically compatible materials having the same primary hazard class, but different subsidiary hazard classes may be packaged together in the same outer container.

The generic description that best describes the waste materials corresponds to the primary hazard class (Class 3) of the materials contained in the lab pack.  The generic description,  "flammable liquid, toxic, corrosive, n.o.s."  is an acceptable generic description for materials shipped in a lab pack when all the subsidiary hazards are present.  However, when materials being shipped in a lab pack have only the toxic or corrosive subsidiary hazards present, the generic descriptions,  " flammable liquid, toxic, n.o.s." or  "flammable liquid, corrosive, n.o.s."  must be selected, as appropriate.
I hope this answers your inquiry.

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


Regulation Sections

Section Subject
173.12 Exceptions for shipment of waste materials