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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 #13-0185 ([Veolia ES Technical Solutions, L.L.C.] [Ms. Jennifer Eberle])

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

Interpretation Response Details

Response Publish Date:

Company Name: Veolia ES Technical Solutions, L.L.C.

Individual Name: Ms. Jennifer Eberle

Location State: NJ Country: US

View the Interpretation Document

Response text:

February 18, 2014

Ms. Jennifer Eberle
Manager, Transportation Compliance
Veolia ES Technical Solutions, L.L.C.
1 Eden Lane
Flanders, NJ 07836

Ref. No. 13-0185

Dear Ms. Eberle:

This is in response to your September 5, 2013 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR 171-180) applicable to preparation of one element of a U.S. Environment Protection Agency (EPA) Uniform Hazardous Waste Manifest (UHWM) when used as an alternative to a shipping paper required by the HMR.  Specifically, you ask whether a net or a gross mass, volume, or activity must be indicated in Block 10 of a UHWM for transportation by modes other than aircraft.  You also state in your letter that if the answer is “yes,” then you are challenging the response in a previously issued interpretation letter, under Ref. No. 13-0052, that indicates otherwise.  

The answer to your question is yes, except as otherwise provided in § 172.202(a)(5), a net or a gross mass, volume, or activity may be indicated on either a shipping paper or a EPA UHWM for transportation by modes other than aircraft.  For transportation by aircraft, entries may only be indicated as the net sum of hazardous materials as prescribed in
§ 172.202(a)(6).  Thank you for bringing this matter to our attention.  We intend to correct our previous response as quickly as possible.

I trust this information is helpful.  Please contact us if you require further assistance.


T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division


Regulation Sections

Section Subject
172.202 Description of hazardous material on shipping papers