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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 #11-0054 ([Environmental Management] [Ms. Misha Gonzales])

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

Interpretation Response Details

Response Publish Date:

Company Name: Environmental Management

Individual Name: Ms. Misha Gonzales

Location State: OK Country: US

View the Interpretation Document

Response text:

March 29, 2011




Ms. Misha Gonzales

Shipping and Receiving

Environmental Management

P.O. Box 700

Guthrie, OK 73044

Ref. No. 11-0054

Dear Ms. Gonzales:

This responds to your February 25, 2011 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask us to clarify the packaging specifications pertaining to certain waste materials that are toxic by inhalation in Hazard Class 6.1, Packing Group I. You indicate that you do not wish to take advantage of the exceptions provided in § 173.12(b). Your questions are paraphrased and answered as follows:

Q1. May we pack four 32-ounce containers of UN1809, Phosphorus trichloride, 6.1 (8), PG I, Hazard Zone B, in one outer container?

A1. The answer to your question is yes, as long as the combination packagings comply with the specifications of § 173.227. Section 173.227(a) allows materials poisonous by inhalation, in Division 6.1, Packing Group I, Hazard Zone B, to be transported in packagings as authorized in § 173.226. Section 173.226(c) specifies combination packaging consisting of an inner packaging system and an outer packaging. The inner packaging system consists of an impact-resistant inner receptacle packed within a leak-tight packaging. This combination packaging in turn is packed within the outer packaging. The total amount of liquid contained in the outer packaging must not exceed 16 L (4 gallons). Both the inner packaging system and the outer packaging must conform to the performance test requirements of subpart M of part 178.

Q2. May we pack two 32-ounce containers of UN1605, Ethylene dibromide, 6.1, PG I, Hazard Zone B, and two containers of UN2487, Phenyl isocyanate, 6.1 (3), PG I, Hazard Zone B, in one outer container?

A2. Yes, provided Ethylene dibromide and Phenyl isocyanate are not capable of reacting dangerously with each other and will not cause combustion or dangerous evolution of heat; evolution of flammable, poisonous, or asphyxiant gases; or formation of unstable or corrosive materials (see §§ 173.21(e) and 173.24(e)(4)). It is the shipper's responsibility to determine whether any of these dangerous reactions can occur. Shippers may use a variety of methods to determine whether or not a hazardous material will react dangerously with other materials in a packaging, including testing or similar analysis, experience, information from a Material Safety Data Sheet, or information from publications or reference material pertaining to chemicals and their interactions.

Q3. If the answer to Q2. Is "yes," may we use the proper shipping description UN2929, Toxic liquid, flammable, organic, n.o.s., (Ethylene dibromide, phenyl isocyanate), 6.1 (3), PG I, Hazard Zone B?

A3. The answer to your question is no. When selecting a proper shipping name, the shipper must select the name that most appropriately describes the material (see § 172.101(c)(12)).

I hope this information is helpful. If you have further questions, please contact this office at (202) 366-8553.


Ben Supko

Acting Chief, Standards Development Branch

Standards and Rulemaking Division

173.12(b), 173.227, 173.266, 173.21, 173.24, 172.101

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table
173.21 Forbidden materials and packages
173.226 Materials poisonous by inhalation, Division 6.1, Packing Group I, Hazard Zone A
173.227 Materials poisonous by inhalation, Division 6.1, Packing Group I, Hazard Zone B
173.24 General requirements for packagings and packages