USA Banner

Official US Government Icon

Official websites use .gov
A .gov website belongs to an official government organization in the United States.

Secure Site Icon

Secure .gov websites use HTTPS
A lock ( ) or https:// means you’ve safely connected to the .gov website. Share sensitive information only on official, secure websites.

U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

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.

Sincerely,

 

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