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

Interpretation Response #09-0006 ([SJ Transportation Co., Inc.] [Mr. Christopher P. Prioli])

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

Interpretation Response Details

Response Publish Date:

Company Name: SJ Transportation Co., Inc.

Individual Name: Mr. Christopher P. Prioli

Location State: NJ Country: US

View the Interpretation Document

Response text:

January 27, 2009

Mr. Christopher P. Prioli

SJ Transportation Co., Inc.

P.O. Box 169

1176 U.S. Route 40

Woodstown, NJ 08098

Ref. No. 09-0006

Dear Mr. Prioli:

This responds to your December 18, 2008 letter and telephone discussions with a member of my staff regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to the transportation of used transformers, rectifiers, and insulating bushings containing PCB"s. Specifically, you ask how these items should be described on the U.S. Environmental Protection Agency (EPA) Form 8700-22, Uniform Hazardous Waste Manifest (UHWM), in terms of type of container. In addition, you ask whether choosing TP (portable tank) on a UHWM would comply with the HMR shipping paper requirements for these items.

The EPA regulates the UHWM, and we cannot answer questions or make interpretations on how best to complete the form. Your questions should be directed to the appropriate EPA Office, including any petitions for changes to EPA regulations or forms.

With respect to whether the abbreviation "TP" on the UHWM satisfies the HMR shipping paper requirements for these PCB contaminated transformers, the answer is no. In accordance with § 172.202(a)(7), a shipping paper must include an indication of the number and type of packages being transported. The abbreviation "TP" which stands for "portable tank," does not accurately describe the stand-alone articles you are shipping. If the UHWM is being used to comply with the HMR shipping paper requirements concerning the number and type of packages, we suggest including further appropriate information (e.g., "4 Transformers") as needed (see Special Provision 81; § 172.102), in Item 14 " Special Handling Instructions & Additional Information, in addition to any other information EPA requires in Item 14. As an alternative, you could create a separate shipping paper meeting all the requirements of Part 172 Subpart C, and transport it along with the UHWM.

I trust this satisfies your inquiry. Please contact us if we can be of further assistance.


Hattie L. Mitchell

Chief, Regulatory Review and Reinvention

Office of Hazardous Materials Standards


Regulation Sections

Section Subject
171.8 Definitions and abbreviations
172.202 Description of hazardous material on shipping papers