USA Banner

Official US Government Icon

Official websites use .gov
A .gov website belongs to an official government organization in the United States.

Secure Site Icon

Secure .gov websites use HTTPS
A lock ( ) or https:// means you’ve safely connected to the .gov website. Share sensitive information only on official, secure websites.

U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #01-0248 ([Fluor Hanford Waste Services] [Mr. Paul W. Martin])

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

Interpretation Response Details

Response Publish Date:

Company Name: Fluor Hanford Waste Services

Individual Name: Mr. Paul W. Martin

Location State: WA Country: US

View the Interpretation Document

Response text:

January 3, 2002


Mr. Paul W. Martin                            Reference No. 01-0248
Fluor Hanford Waste Services/
Waste Management Project
P.O. Box 700
T3-04 MO-279, 200 West Area
Richland, WA 99352-0700

Dear Mr. Martin:

This responds to your facsimiles and telephone conversations with staff members of this office on the correct classification under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) of high-pressure, sodium-vapor lamps being transported for disposal.  You state that these lamps will be transported in bulk, and that many will be crushed as they are packaged.  I apologize for the delay in responding and any inconvenience it may have caused.

The two material safety data sheets (MSDS) you provided describe one lamp as containing the following materials:

Chemical Name Percent by Weight
Barium compound
Lead solder
Lead Borosilicate Glass
Aluminum Oxide

0. 02< 0.1

The second lamp contains the following materials:

Chemical Name
Percent by Weight

no data given.

Neither MODS describes the lamps as meeting an HMR hazard class or provides a protocol for transporting crushed lamps in bulk.  One MODS states the sodium in the lamps may produce heat when in contact with water, but the amount of sodium in a single lamp is so small it generally presents no hazard.  Both MODS's prescribe methods for handling mercury vapor, lead dust, and other chemicals and materials the lamps contain.

Under § 173.22, it is the shipper's responsibility to determine the hazard class for a hazardous material.  This office does not perform that function.  However, based on the information you provided, we agree with your determination that a bulk package filled with the crushed lamps would contain a sufficient amount of hazardous material to meet the definition of a Division 4.3 material in § 173.124. You should also determine if the package contains a sufficient amount of lead, mercury, or sodium to meet the definition in § 171.8 for a hazardous substance.  Further, we agree with your determination that an uncrushed lamp, provided it is not packaged with or contaminated by material from a crushed lamp, is not regulated as a hazardous material under the HMR.

I hope this information is helpful.



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


Regulation Sections

Section Subject
173.22 Shipper's responsibility