Interpretation Response #98-0394 ([State of Connecticut] [Mr. Tom Metzner])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: State of Connecticut
Individual Name: Mr. Tom Metzner
Location State: CT Country: US
View the Interpretation Document
Response text:
APR 23, 1998
Mr. Tom Metzner
Waste Bureau, Source Reduction
and Recycling Program
State of Connecticut
Department of Environmental Protection
79 Elm Street
Hartford, CT 06106
Dear Mr. Metzner:
This is in response to your inquiry regarding the applicability of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171¬180) for the shipment of waste fluorescent light bulbs.
Specifically, you ask whether the shipping description "Hazardous waste, solid, n.o.s. (D009), 9, NA3077, PG III" or "Mercury contained in manufactured articles, 8, UN2809, PG I" is the appropriate shipping description for waste fluorescent light bulbs being transported by highway. For waste fluorescent light bulbs containing only trace amounts of mercury vapor, "Hazardous waste, solid, n.o.s. (D009), 9, NA3077, PG III" is the correct shipping description. "Mercury contained in manufactured articles, 8, UN2809, PG I" would apply as the shipping description for mercury meeting the corrosive d~finition in § 173.136. As indicated by the letter "A" in Column 1 of the Hazardous Materials Table, "Mercury, UN2809" is regulated only by air unless it is a hazardous waste or a hazardous substance (see § 171.8), in which case it is regulated by all modes. An exception in § 172.101(f) permits Packing Group III packagings for modes of transportation other than the mode indicated in Column 1.
With regard to the packaging requirements, "Hazardous waste, solid, n.o.s. (D009), 9, NA3077, PG III" must be packaged in . accordance with the requirements specified in § 173.213. Packaging exceptions for limited quantities may be found in § 173.155. Packaging authorizations for "Mercury contained in manufactured articles, 8, UN2809, PG I" must be packaged in accordance with the requirements specified in § 173.164, and, as provided in § 173.164(c), are excepted from specification packaging if packaged in accordance with paragraph (c) (1). Packagings also must conform to the general requirements for transportation by aircraft contained in § 173.27.
I hope this information is helpful. If we may be of further assistance, please do not hesitate to contact this office.
Sincerely,
Hattie L. Mitchell, Chief
Exemptions and Regulations Termination
Office of Hazardous Materials Standards
172 APPENDIX A