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Interpretation Response #00-0310 ([Radian International] [Mr. Andrew N. Romach])

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

Interpretation Response Details

Response Publish Date:

Company Name: Radian International

Individual Name: Mr. Andrew N. Romach

Location State: NC Country: US

View the Interpretation Document

Response text:

January 18, 2001


Mr. Andrew N. Romach                 Reference. No. 00-0310
Regulatory Manager
Radian International
P.O. Box 13000
Research Triangle Park, NC 27709

Dear Mr. Romach:

This is in response to your November 2, 2000, letter regarding the proper shipping name for a material consisting of polychlorinated biphenyls (PCBs) and soil under the Hazardous Materials Regulations (49 CFR Parts 171-180).  Your scenario consists of a bulk packaging being transported by highway containing more than I pound of pure PCBs at a concentration of more than 20 ppm but less than 50 ppm. You question whether the proper shipping name “Polychlorinated biphenyls, solid” is appropriate for a material with such a low concentration of PCBs.

As provided by § 172.101 (c)(10), a mixture not identified specifically by name, comprised of a hazardous material identified in the Table by technical name (e.g.,PCBs) and non-hazardous material (e.g., soil), must be described using the proper shipping name of the hazardous material and the qualifying word “mixture” unless the mixture is significantly different from the pure hazardous material (i.e., meets a different hazard class or packing group or there is a significant change in emergency response measures).  Therefore, in the scenario you provided, the proper shipping description is “Polychlorinated bipheyls, solid, mixture, 9, UN 2315, III” when transported by highway.  Note that the packing group changes from    “II” to “III” when this material is transported by highway or rail as stated in Special Provision 140.

I hope this information is helpful.



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


Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table