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Interpretation Response #09-0156 ([PSC Environmental Services, LLC] [Mr. James V. Levitz])

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

Interpretation Response Details

Response Publish Date:

Company Name: PSC Environmental Services, LLC

Individual Name: Mr. James V. Levitz

Location State: IN Country: US

View the Interpretation Document

Response text:

July 31, 2009



Mr. James V. Levitz

PSC Environmental Services, LLC

6405 Thornridge Drive

Avon, IN 46123

Ref. No. 09-0156

Dear Mr. Levitz:

This responds to your July 1, 2009, letter requesting clarification on assigning generic shipping descriptions to specific materials with a fixed description under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether the list of fixed description entries provided in your letter may also be assigned a generic shipping name under the provisions for lab packs in §173.12(b).

In your letter, you reference a previous letter of clarification (Ref. No.07-0144; March 4, 2008) in which we stated that it is permissible to package specific materials with a fixed description, such as aniline and phenol, under the lab pack provisions in §173.12(b), and use a generic shipping description in place of the specific fixed description. You note that there are additional entries, listed in your letter, that may also qualify under the §173.12(b) provisions. You ask whether these additional listed materials qualify for the use of the generic shipping description under the lab pack provisions in §173.12(b).

The answer is yes. The additional materials with fixed shipping descriptions listed in your letter that meet the hazard class/divisions specified in §173.12(b) may be transported using a generic shipping description instead of the fixed description as provided in paragraph (b)(1) of §173.12.

I hope this answers your inquiry.


Charles E. Betts

Chief, Standards Development

Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.12 Exceptions for shipment of waste materials