Interpretation Response #04-0282 ([Rebec LLC] [Mr. Michael K. Jeffers])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Rebec LLC
Individual Name: Mr. Michael K. Jeffers
Location State: WA Country: US
View the Interpretation Document
Response text:
May19, 2005
Mr. Michael K. Jeffers Reference No. 04-0282
Compliance Manager
Rebec LLC
P.O. Box 658
Edmonds, WA 98020
Dear Mr. Jeffers:
This is in response to your letter dated December 6, 2004, concerning our November 24, 2004 letter, regarding the identification of dental amalgam as a hazardous substance under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you provide documentation to support your view that dental amalgam is not a hazardous substance.
Dental amalgams contain mercury metal alloyed with silver and smaller amounts of other metals. As we stated in our November 24, 2004 letter, mercury is regulated as a hazardous substance under the HMR. Thus, when dental amalgam is offered for transportation in commerce, the shipment is subject to all applicable HMR requirements.
I hope this information is helpful.
Sincerely,
Susan Gorsky Acting Director
Office of Hazardous Materials Standards
172.101
Appendix A