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Interpretation Response #07-0105 ([General Environmental Management, Inc.] [Alexander Amort])

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

Interpretation Response Details

Response Publish Date:

Company Name: General Environmental Management, Inc.

Individual Name: Alexander Amort

Location State: CA Country: US

View the Interpretation Document

Response text:

Jun 6, 2007


Alexander Amort                 Reference No. 07-0105


General Environmental Management, Inc.

11855 White Rock Road

Rancho Cordova, CA 95742

Dear Mr. Amort:

This is in response to your May 21, 2007 letter requesting clarification of the basic description sequence on shipping papers provided in § 172.202 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask you ask if the recent change under the final rule to Docket HM-2 151 (71 FR 78595; January 1, 2006), requiring the sequence to be rearranged so the identification number is first, followed by the proper shipping name, hazard class, and packing group and no other information interspersed, will cause a problem with the requirement in § 172.101(c)(9) to add the modifying word "waste" preceding the proper shipping name for hazardous wastes that are not identified by the word "waste." You indicate that adding the word "waste" forces the shipper to violate the requirement in § 172.202(b) indicating that no additional information may be interspersed within the basic description.

We understand and appreciate your concerns. Prior to the publication of Docket HM-2151 we considered the same issues you cover in your letter. We concluded that the requirement in § 172.101(c)(9) to add the word "waste" preceding the proper shipping name for hazardous wastes that are not identified by the word "waste" causes the proper shipping name to be modified. The word "waste" becomes part of the proper shipping name. Therefore, when the word "waste" is added to the beginning of a proper shipping name as prescribed in § 172.10l(c)(9) and then added to the basic description as part of the proper shipping name, it is not considered a violation of the requirements in § 172.202(b).

I hope this information is helpful. Please contact us if you require additional assistance.


John A. Gale

Chief, Standards Development

Office of Hazardous Materials Standards

172.101(c)(9), 172.202 (b)

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table
172.202 Description of hazardous material on shipping papers