Interpretation Response #10-0256 ([Clean Venture, Inc.] [Mr. Roy H. Swartz])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Clean Venture, Inc.
Individual Name: Mr. Roy H. Swartz
Location State: MA Country: US
View the Interpretation Document
Response text:
March 4, 2011
Mr. Roy H. Swartz
Manager of Regulatory Compliance
Clean Venture, Inc.
138 Leland Street
Framingham, MA 01702
Ref. No.: 10-0256
Dear Mr. Swartz:
This responds to your November 19, 2010 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You have provided an example of a hazardous waste manifest. Column 9B of the manifest contains the following proper shipping description "RQ, Waste Trichloroethylene, 6.1, UN1710, PGIII." Column 10 includes the number and type of packages "6 DM/DF," where DM stands for metal drum and DF stands for fiber drum. In column 14, additional information is provided "Line 4 - 4DM, 2DF". Specifically, you ask if two types of packages (e.g., DM/DF) entered in association with a single basic description for a hazardous material would satisfy the shipping paper requirement to list the number and type of packages as part of the shipping description.
The answer is yes. The HMR require the number and type of packages to be entered as part of the shipping description on a shipping paper (§ 172.202(a)(7)). The abbreviations DM and DF are used on hazardous waste manifests to indicate the presence of metal and fiber drums. Thus, the example you provided, which lists the number and type of packages in column 10 of a hazardous waste manifest as "6 DM/DF" for the shipping description satisfies the HMR requirement in § 172.202(a)(7).
In addition, you asked about compliance with the Compliance, Safety, Accountability (CSA) 2010 program. The Federal Motor Carrier Safety Administration implements the CSA 2010 program. Information on CSA 2010 is available at the following website: http://csa.fmcsa.dot.gov/.
I trust this satisfies your inquiry. Please contact us if we can be of further assistance.
Sincerely,
Ben Supko
Acting Chief, Standards Development Branch
Standards and Rulemaking Division
172.202(a)(7)
Regulation Sections
| Section | Subject |
|---|---|
| 172.202 | Description of hazardous material on shipping papers |