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Interpretation Response #00-0355 ([Safety-Kleen Inc] [Ms. Jean M. Soltys])

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

Interpretation Response Details

Response Publish Date:

Company Name: Safety-Kleen Inc

Individual Name: Ms. Jean M. Soltys

Location State: MA Country: US

View the Interpretation Document

Response text:

January 26, 2001


Ms. Jean M. Soltys                      Ref. No. 00-0355
Environmental Manager
Safety-Kleen Inc.
221 Sutton Street
North Andover, MA 01845

Dear Ms. Soltys:

This is in response to your December 12, 2000 letter, regarding the use of the shipping name, “Environmentally Hazardous Substance, (liquid or solid), nos”  under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).

The proper shipping name, “Environmentally Hazardous Substance, (liquid or solid), nos,”  may be used for a material not specifically listed in § 172.101, which meets the definition of a Class 9 material.  A material need not meet the definition of a hazardous substance in § 171.8 to be associated with this proper shipping name.

A material can meet the Class 9 definition for reasons other than being a hazardous substance.  Further, while the United States Environmental Protection Agency does not require the use of a manifest for universal wastes, certain states have not adopted parts or all of the Universal Waste program.  Therefore, if a material is subject to the Uniform Hazardous Waste Manifest in 40 CFR Part 262 in a particular state, the material will, at minimum, meet the definition of a “hazardous waste” under § 171.8.

I hope this satisfies your request.



Transportation Regulations Specialist
Office of Hazardous Materials Standards



Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table