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Interpretation Response #03-0072 ([New York State Department of Environmental Conservation Division of Solid and Hazardous Materials] [Mr. Paul R. Counterman, P.E.])

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

Interpretation Response Details

Response Publish Date:

Company Name: New York State Department of Environmental Conservation
Division of Solid and Hazardous Materials

Individual Name: Mr. Paul R. Counterman, P.E.

Location State: NY Country: US

View the Interpretation Document

Response text:

May 7, 2003


Mr. Paul R. Counterman, P.E.                Reference No. 03-0072
Director, Bureau of Hazardous Waste Management
New York State Department of Environmental Conservation
Division of Solid and Hazardous Materials
625 Broadway
Albany, NY 12233-7251

Dear Mr. Counterman:

This is in response to your February 18, 2002 letter, requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) on the proper shipping name and appropriate packaging for industrial rags.  Specifically, you request written confirmation that the proper shipping name should be “Solids containing corrosive liquid, n.o.s”, “Solids containing flammable liquid, n.o.s.” or “Solids containing toxic liquid, n.o.s.” if any amount of corrosive, flammable or toxic liquids are present in the rags,

In accordance with § 173.22, it is the responsibility of the shipper to select the shipping name that most accurately reflects the material being shipped. The shipper must also determine the packaging or container in an authorized packaging, including part 173 requirements, and that it has been manufactured, assembled, and marked in accordance with the HMR.

The proper shipping names you listed can be used for the shipment and transportation of industrial rags containing various hazardous materials.  The Hazardous Materials Table (HMT), § 172.101, provides Special Provisions for each of the proper shipping names: Special Provision 49 for corrosive liquids; Special Provision 47 for flammable liquids; and Special Provision 48 for toxic liquids.  These Special Provisions state that this material may be transported under the above proper shipping names without first applying the classification criteria, provided there is no free liquid visible at the time the material is loaded or at the time the packaging or transport unit is closed.  Authorized packagings are identified in §§ 173.212 and 173.240 for non-bulk and bulk packaging, respectively.  Packaging exceptions are identified in §§ 173.154 and 173.151 for corrosive liquids and flammable liquids, respectively.

I hope this information is helpful.  If we can be of further assistance, do not hesitate to contact us.



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


Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table