Interpretation Response #98-0356 ([CYS Management Services, Inc.] [Ms. Jodi Smith])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: CYS Management Services, Inc.
Individual Name: Ms. Jodi Smith
Location State: AK Country: US
View the Interpretation Document
Response text:
JAN 13, 1999
Ms. Jodi Smith Ref. No. 98-0356
CYS Management Services, Inc.
P.O. Box 35386
Fort Wainwright, AK 99703
Dear Ms. Smith:
This is in response to your letter and subsequent telephone conversations with members of my staff. Your question concerns how to determine what constituents need to be identified when using a generic proper shipping name under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).
Section 172.203(k) states that if a hazardous material is a mixture or solution of two or more hazardous materials, the technical names of at least two components most predominantly contributing to the hazards of the mixture must be entered on the shipping paper.
In your letter you indicated you had a mixture of waste antifreeze and water and that the antifreeze contains lead. This material is classified as a Class 9 material because it is a hazardous waste and meets no other hazard class. In this instance, the material is regulated as a hazardous waste for lead. Therefore, the technical name for your material would be either "lead" or "D008." The propylene glycol does not contribute to the Class 9 hazard so it does not need to be included in association with the shipping name.
I hope this satisfies your request.
Sincerely,
John A. Gale
Transportation Regulations Specialist
Office of Hazardous Materials Standards
172.203
Regulation Sections
| Section | Subject |
|---|---|
| 172.203 | Additional description requirements |