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Interpretation Response #06-0039 ([Shane Havoc Consulting, LLC] [Dr. Gregory J. Sutherland ])

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

Interpretation Response Details

Response Publish Date:

Company Name: Shane Havoc Consulting, LLC

Individual Name: Dr. Gregory J. Sutherland 

Location State: SC Country: US

View the Interpretation Document

Response text:

Mar 23, 2006

Dr. Gregory J. Sutherland                Reference No. 06-0039
Shane Havoc Consulting, LLC
1905 English Ivy Ct.,
Mt. Pleasant, SC 29464

Dear Dr. Sutherland:

This is in response to your February 5, 2006 letter requesting clarification regarding the appropriate proper shipping name for your material as specified under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if your client’s material, which does not meet the definition of any hazard class except Class 9 for hazardous waste, may be shipped in its original (non-specification) packaging and described as “Environmentally Hazardous Substances, Liquid, n.o.s. (D002), 9, UN 3082, PG III.”

Under § 173.22, it is the shipper’s responsibility to properly classify a hazardous material and assign it a proper shipping name from the Hazardous Materials Table (HMT). Based on the information provided in your letter and to a member of my staff, it is the opinion of this office that the material should be described as “Hazardous Waste, Liquid, n.o.s (DO0:2), 9, NA 3082, PG III.” The material may be offered for transportation in non-bulk packaging in accordance with § 173.203. Section 173.203 does not authorize non-specification packagings; therefore, the original packaging may not be used.

I hope this information is helpful.



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

172.101, 173.22, 173.203

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table
173.203 Non-bulk packagings for liquid hazardous materials in Packing Group III
173.22 Shipper's responsibility