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Interpretation Response #01-0302 ([Dinda and Associates, Inc.] [Mr. John F. Dinda, Jr.])

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

Interpretation Response Details

Response Publish Date:

Company Name: Dinda and Associates, Inc.

Individual Name: Mr. John F. Dinda, Jr.

Location State: PA Country: US

View the Interpretation Document

Response text:

March 1, 2002


Mr. John F. Dinda, Jr.                          Reference No. 01-0302

Dinda and Associates, Inc.

525 Shady Retreat Road

Doylestown, PA 18901

Dear Mr. Dinda:

This responds to your November 30, 2001 letter requesting clarification on § 173.240 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you ask whether you may co-load "Waste toxic solids, n.o.s.(carbofuran, carbosulfan), 6.1, UN 2811, PG III" with other PG I and PG II packaged waste materials in the same siftproof closed vehicle.

According to your letter, FMC Corporation filed an application for exemption on August 16, 2001, to allow non-specification packaging to be used for baled Division 6.1, PG III hazardous waste and co­loaded on the same vehicle with other PG I and PG H packaged hazardous waste materials.  You wish to confirm that co-loading of other PG  I and PG II  packaged waste with PG III waste materials in the same siftproof closed vehicles is permitted.

Section 173.240, authorizes the use of siftproof closed vehicles as bulk packagings for certain low hazard solid materials, such as PG III waste materials.  Provided, the PG I and PG II  waste materials are properly packaged and otherwise comply with the HMR, they may be co-loaded with PG III  waste materials in the same siftproof closed transport vehicle.  In addition, if the PG III  waste materials are co­loaded with other PG I and PG II packaged waste materials, they must also meet compatibility requirements in § 173.2 1.

I hope this answers your inquiry.



Delmer F. Billings

Chief, Standards Development

Office of  Hazardous Materials Standards


Regulation Sections

Section Subject
173.240 Bulk packaging for certain low hazard solid materials