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Interpretation Response #02-0123 ([Waste Management, Inc] [DonnaAmes-Cassick])

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

Interpretation Response Details

Response Publish Date:

Company Name: Waste Management, Inc

Individual Name: DonnaAmes-Cassick

Location State: NY Country: US

View the Interpretation Document

Response text:

June 18, 2002

Ms. Donna Ames-Cassick                    Reference No. 02-0123
Compliance Manger
Waste Management, Inc.
P.O. Box 200
Model City, NY 14107

Dear Ms. Ames-Cassick:

This is in response to your April 24, 2002 letter regarding the packing group for polychlorinated biphenols (PCBs) under the Hazardous Materials Regulations (HMR; 49 CFR parts 171-180).  Specifically, you ask if polychlorinated biphenols should be considered a packing group II or III material when transported by highway.

According to Special Provision 140 in appendix A of the Hazardous Materials Table (HMT) in § 172. 101, if transporting PCBs by rail or highway, the packing group is changed to PG III instead of PG II as listed in the HMT.  Since PCBs can be both a packing group II and III material, depending on mode, if you wish to consider PBS as a packing group II material when transporting it by highway, you may do so.  Please note that we will be removing the "A" and "W" from column one of the HMT for the entry "PCB" in an upcoming corrections notice to be published in the Federal Register.

I hope this satisfies your request.


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


Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table