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Interpretation Response #06-0039R ([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:

December 3, 2009




Dr. Gregory J. Sutherland

Shane Havoc Consulting, LLC

1905 English Ivy Ct.,

Mt. Pleasant, SC 29464

Ref. No. 06-0039R

Dear Dr. Sutherland:

This is in further reference to our March 23, 2006 response of 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 that is being shipped to an EPA approved TSDF facility, 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." In this letter we are clarifying the acceptable shipping descriptions.

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 may be described as either "UN 3082, Environmentally Hazardous Substances, Liquid, n.o.s. (D002), 9, PG III" or "NA 3082, Hazardous Waste, Liquid, n.o.s (D002), 9, PG III" for domestic transportation. 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 of Hazardous Materials Standards


Regulation Sections

Section Subject
173.22 Shipper's responsibility