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Interpretation Response #17-0072

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

Interpretation Response Details

Response Publish Date:

Company Name: Navarro Research and Engineering, Inc

Individual Name: Lee Stevens

Location State: NV Country: US

View the Interpretation Document

Response text:

November 09, 2017
Lee J. Stevens
Radioactive Waste Acceptance Program
Office of Environmental Management Nevada Program
c/o Navarro Research and Engineering, Inc.
232 Energy Way
North Las Vegas, NV 89030
Reference No. 17-0072
Dear Mr. Stevens: 
This letter is in response to your July 20, 2017, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). 
We have paraphrased and answered your questions as follows:

Q1. You ask if the proper shipping description "UN3321, Radioactive material, low specific activity (LSA-II) fissile excepted, 7" complies with the HMR when used to describe an appropriately characterized and classed material that is transported by highway.

A1. The answer is yes.  Section 172.101(c)(2) permits words in italics that appear as part of a proper shipping name in the Hazardous Materials Table (HMT; § 172.101) to be included as part of the proper shipping name.  However, please note the HMT entry you reference includes a hyphen between the words "fissile" and "excepted."

Q2. Provided the proper shipping description in Question Q1 complies with the HMR, you ask if the words "fissile-excepted" must be added in association with or after that description, along with any other applicable entries required by § 172.203(d).

A2. The answer is yes.

    I hope this information is helpful.  Please contact us if we can be of further assistance.


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


    172.101(c)(2), 172.101, 172.203(d)

    Regulation Sections

    Section Subject
    172.101 Purpose and use of hazardous materials table
    172.203 Additional description requirements