Interpretation Response #99-0012 ([Safety-Kleen Corporation] [Mr. Jerry Davis])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Safety-Kleen Corporation
Individual Name: Mr. Jerry Davis
Location State: SC Country: US
View the Interpretation Document
Response text:
September 7, 1999
Mr. Jerry Davis Ref. No. 99-0012
Safety-Kleen Corporation
1301 Gervais Street, Suite 300
Columbia, South Carolina 29201
Dear Mr. Davis:
This is in response to your letter asking if it is acceptable for Safety-Kleen Corporation to include the technical names of several different waste mixtures and solutions, having the same proper shipping name, hazard class, and identification number, in block "15" of a Uniform Hazardous Waste Manifest (UHWM ). For example, several different wastes from several different generators are described on the UHWM using a generic shipping name, such as "Waste flammable liquid, n.o.s., 3, UN 1993, PG II." The technical names for these different wastes are entered in block "15" of the UHWM. I apologize for the delay in responding and hope it has not caused any inconvenience.
Under the HMR, both the basic description and any additional descriptive information required to be associated with the basic description under the provisions of 49 CFR 172.203, should appear in block "11"of the UHWM. Any additional information required by 49CFR 172.203 that is required to be placed "in association with the basic description" may follow the basic description in any reasonable format, provided it is clearly part of that specific entry. Although it is preferable to use block "11," in those instances where only one hazardous material description is entered on the UHWM, block “J” in addition to block "11" may be used to include the technical name entries.
Thus, no exemption is required when only one basic description is used to describe several generators hazardous wastes on the UHWM, provided the packages contain hazardous wastes with the sarne proper shipping name, hazard class, identification number, and packing group, and block “J” is used to identify the technical names of the constituents of the mixtures or solutions.
I hope this satisfies your inquiry. If we can be of further assistance, please contact us.
Sincerely,
Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards
172.203
Regulation Sections
| Section | Subject |
|---|---|
| 172.203 | Additional description requirements |