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Interpretation Response #02-0276


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

Interpretation Response Details

Response Publish Date: 01-02-2003
Company Name: Duratek Federal Services, Inc    Individual Name: James H. Portsmouth
Location state: WA    Country: US

View the Interpretation Document


Response text:

Jan 2, 2003

Mr. James H. Portsmouth                   Reference No. 02-0276
Traffic Manager
Duratek Federal Services, Inc
345 Hills Street
Richland, WA 99352-0700

Dear Mr. Portsmouth:

This is in response to your letter requesting clarification of the shipping paper and marking requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).

You state the material is a hazardous waste subject to the EPA Uniform Hazardous Waste Manifest requirements and is described in accordance with § 172-203(d) as "Waste Radioactive material, LSA, n.o.s., 7, UN2912." This material does not meet or exceed the reportable quantity (RQ) for any radionuclide; however, it does meet the definition of a hazardous substance in § 171.8 for waste code D008.

Your questions are paraphrased and answered as follows:

Q1. Is the offeror of this material required to identify the hazardous substance by name or waste code in parentheses as a shipping paper entry or marking in accordance with §§ 172.203(c)(1) and 172.324(a) respectively?

A1. The answer is no.  If a Class 7 material is described and labeled in accordance with §§ 172.203(d) and 172.403(g) respectively, the waste code of the hazardous substance required by §§ 172.203(c) and 172.324 does not have to be identified on the shipping paper and on the package-

Q2. Is it permissible to enter the hazardous constituent in parentheses as additional information on the shipping paper when the information is not required by § 173.203(c)(1)?

A2. The answer is yes.

I hope this satisfies your request.

Sincerely,

Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards

172.203, 172.324


Regulation Sections

Section Subject
§ 172.203 Additional description requirements