Interpretation Response #05-0291 ([Environmental Waste Specialist, Inc] [Ms. Elizabeth Novak])

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

Interpretation Response Details

Response Publish Date: 12/20/2005

Company Name: Environmental Waste Specialist, Inc

Individual Name: Ms. Elizabeth Novak

Location State: VA Country: US

View the Interpretation Document

Response text:

Dec 20, 2005

Ms. Elizabeth Novak                      Ref. No. 05-0291
Environmental Waste Specialist, Inc.
14100 Sullyfield Circle, Suite 400
Chantilly, VA 20151

Dear Ms. Novak:

This is in response to your letter requesting additional clarification of our response (Ref No. 05-0260, November 4, 2005) to your request for interpretation of the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to shipments of asbestos contained in manufactured products. Specifically, you ask whether Special Provision 156 applies to asbestos products that have been broken.

If the broken, manufactured products are crumbling or brittle such that the asbestos is no longer contained in the manufactured article (friable), Special Provision 156 does not apply. A friable asbestos-containing material is regulated as a hazardous substance under the HMR when packaged in quantities of one pound or more of friable asbestos in one package.

I hope this information is helpful.

Sincerely,

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

172.102 sp 156

Regulation Sections