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Interpretation Response #00-0055 ([Lead Industries Association, Inc.] [Mr. Jeffrey T. Miller])

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

Interpretation Response Details

Response Publish Date:

Company Name: Lead Industries Association, Inc.

Individual Name: Mr. Jeffrey T. Miller

Location State: NJ Country: US

View the Interpretation Document

Response text:

March 17, 2000

                Ref. No. 00-0055

Mr. Jeffrey T. Miller
Lead Industries Association, Inc.
13 Main Street
Sparta, NJ 07871

Dear Mr. Miller:

This is in response to your letter and subsequent telephone conversation with a member of my staff concerning the classification for lead compounds under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).
Specifically, you request clarification pertaining to the use of the entry "Lead compounds, soluble, n.o.s." and whether you must consider the results of the solubility test in Special Provision 138.  You state that your lead compounds do not meet the definition of Division 6.1 under § 173.132 and that they are not hazardous wastes, hazardous substances, or marine pollutants.

Special Provision 138 does not apply in your situation.  Your material does not meet the definition of Division 6.1; therefore, you may not use the entry, "Lead compounds, soluble, n.o.s.". Under the HMR, unless an entry is preceded by a plus (+) sign in Column (1) of the HMT, a material listed by name that does not meet the corresponding hazard class may not be described using that description.  If you determine that your material meets the definition of another hazard class, you must choose the most appropriate proper shipping name with a hazard class assignment applicable to the material.  If you determine that the material does not meet the definition of another hazard class and is not a hazardous substance, hazardous waste or marine pollutant, then the material is not subject to the HMR.

I hope this information is helpful.  Please contact this office if you need additional assistance.


Hattie L. Mitchell, Chief
Regulatory Review and Reinvention
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.132 Class 6, Division 6.1-Definitions