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Interpretation Response #00-0107 ([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:

May 16, 2000

Mr. William J. Briner                Ref. No. 00-0107
Regulatory Affairs Manager
Monsanto Company
800 North Lindbergh Blvd.
St. Louis, MO 63167

Dear Mr. Briner:

This is in response to your letter dated April 6, 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 known to be 100 percent ethanol would meet the definition of a hazardous substance under §171.8.

The answer is yes.  The appropriate RQ for a hazardous waste (e.g., D001) made up entirely of a material not specifically listed under Appendix A to §172.101 is that which is assigned to the waste (e.g., D001).  Therefore, waste ethanol is subject to the RQ for a D001 waste (100 pounds (454 kg)). 

I hope this satisfies your request.


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


Regulation Sections

Section Subject
171.8 Definitions and abbreviations