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Interpretation Response #02-0084

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

Interpretation Response Details

Response Publish Date: 07-10-2002
Company Name: US Liquids of Georgia Solvent Division    Individual Name: JoanVan Matre
Location state: GA    Country: US

View the Interpretation Document

Response text:

JUL 10, 2002

Ms. Joan Van Matre                                         Ref. No.: 02-0084
US Liquids of Georgia Solvent Division
1184 Logan Circle
Atlanta, GA 30318

Dear Ms. Van Matre:

This responds to your March 18, 2002 letter requesting clarification on shipping paper documentation and placarding under the Hazardous Materials Regulations (HMR.; 49 CFR Parts 171-180). Specifically, you ask the correct shipping description and proper placard required for your non-bulk and bulk shipments of combustible plate wash solvent.

According to your letter, you ship a plate wash solvent that you have classed as a "Combustible liquid" in 55-gallon drums and in 275-gallon totes. The shipping papers attached with your letter are not in compliance with the HMR. The basic shipping description (the proper shipping name, hazard class number, UN identification number, and packing group number) is incorrect. Regarding the sequence. of information, the type of packaging, e.g., "drums, (55, gal)" may be entered before or after the basic . description. Any additional information concerning the material must be placed after the basic description required by § 172.202(a).

In addition, "plate wash solvent" is not a proper shipping name or proper technical name. Generic shipping paper entries such as "Combustible liquid, n.o.s.", requires a technical name or chemical name ofthe ingredient that makes the material combustible. A technical name is a recognized chemical name or microbiological name currently used in scientific and technical handbooks, j ournals, and texts. Generic descriptions are authorized for use as a technical names provided they readily identify the general chemical group, or microbiological group. Examples of acceptable generic chemical descriptions are organic phosphate compounds, petroleum aliphatic hydrocarbons and tertiary amines. Trade names may not be used as technical names.

The following is an example of a proper shipping description for a "Combustible liquid, n.o.s," material:

1 tote, Combustible liquid, n.o.s.(proper technical name), NA 1993, 400 lbs.

In response to your placarding question, if you meet provisions in § 173.150(f}, the non-bulk (55-gallon drum) shipment of the plate wash solvent is not subject to the HMR, including shipping paper, marking, labeling, and placarding, unless it is a hazardous waste. hazardous substance, or marine pollutant.

However, the bulk (tote) shipment of the plate wash solvent is subject to the HMR as stated in § 173.150(f) and must be properly described on the shipping paper, marked, packaged, and placarded. Each bulk package must be marked with the UN identification number as specified in §§ 172.302 and 172.322. In accordance with § 172.504(a), each bulk packaging, freight container, unit load device, transport vehicle, or rail car containing any quantity of a hazardous must be placarded on each side and each end with the type of placards specified in tables 1 or 2 of this subpart. In addition, under § 172.514( c), a tote or portable tank having a capacity of less than 3,785 L (1,000 gallons) may be placarded on only two opposite sides or, alternatively, may be labeled instead of placarded. For your information, there is no combustible label authorized in the HMR. A placard on a tote may be used to meet vehicle placarding if it is visible on all four sides; however, if the bulk package is inside a freight container or transport vehicle and the placards are not visible, the motor vehicle must be placarded on all four sides and the UN identification number displayed.

I hope this answers your inquiry.


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

Regulation Sections

Section Subject
§ 172.101 Purpose and use of hazardous materials table