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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 #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:

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


Ben Supko

Acting Chief, Standards Development Branch

Standards and Rulemaking Division


Regulation Sections

Section Subject
172.202 Description of hazardous material on shipping papers