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Interpretation Response #00-0025 ([Monsanto Company] [Mr. William J. Briner])

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

Interpretation Response Details

Response Publish Date:

Company Name: Monsanto Company

Individual Name: Mr. William J. Briner

Location State: MO Country: US

View the Interpretation Document

Response text:

March 10, 2000

Mr. William J. Briner                Ref.  No. 00-0025
Regulatory Affairs Manager
Monsanto Company
800 North Lindbergh Blvd.
St. Louis, MO 63167

Dear Mr. Briner:

This is in response to your letter dated January 13, 2000, regarding the definition of a hazardous substance under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you ask whether a package containing 400 pounds of a D001 waste, the composition of which is known to be 100% mineral spirits, would exceed its reportable quantity (RQ) as stipulated under Appendix A to § 172.101.

The appropriate RQ for a hazardous waste depends on the amount of information available on the waste stream including the constituents of the waste stream and their respective concentrations.  If the constituent and its exact concentration in the waste stream are known, then the RQ for the constituent is appropriate.  For example, Toluene has an RQ of 1000 pounds (454 kg).  If Toluene is the only constituent and its concentration in a mixture or solution is known, then the RQ for Toluene is appropriate.  However, if the waste's constituent or its respective concentration is unknown, then the appropriate RQ is that which is assigned to the waste stream.  Therefore, you must know the constituents and their exact concentration in the mineral spirits, otherwise the material is subject to the RQ for a D001 waste (100 pounds (454 kg)).

I hope this satisfies your request.
Sincerely,

John A. Gale
Transportation Regulations Specialist
Office of Hazardous Materials Standards

171.8

Regulation Sections

Section Subject
171.8 Definitions and abbreviations