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Interpretation Response #06-0168 ([Oak Ridge National Laboratory] [Mr. Herb Debban ])

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

Interpretation Response Details

Response Publish Date:

Company Name: Oak Ridge National Laboratory

Individual Name: Mr. Herb Debban 

Location State: TN Country: US

View the Interpretation Document

Response text:

Sep 12, 2006


Mr. Herb Debban                 Reference No. 06-0168
Director, Facilities and Operations Directorate
Oak Ridge National Laboratory
P.O. Box 2008
Oak Ridge, Tn 37831-6257

Dear Mr. Debban:

This is in response to your June 26, 2006 letter concerning how to select the correct proper shipping name for a lab pack containing two types of Division 4.1 (flammable
solid) materials under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). In your example, you state the outer package contains five bottles, three that contain organic compounds and two that contain inorganic metal powders. Because there is no generic flammable solid proper shipping name without the word “organic” or “inorganic’ on the Hazardous Materials Table (HMT; § 172.101), you ask if you must choose one of these names to describe the lab pack or if a generic proper shipping name for each material must be used.

The lab pack exception in § 173.12(b) allows a shipper to use a generic proper shi name in place of specific chemical names to represent two or more compatible waste materials of the same hazard class in the same outside packaging provided the items are packaged, described, and transported in accordance with this section. If an appropriate generic proper shipping name to describe all the materials within the package is not provided in the HMR, either the generic or specific proper shipping name for each material contained within the package may be used.

I hope this information is helpful.



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

172.101, 173.12 (b)

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table
173.12 Exceptions for shipment of waste materials