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Interpretation Response #99-0096 ([American Trucking Associations] [Mr. Paul Bomgardner])

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

Interpretation Response Details

Response Publish Date:

Company Name: American Trucking Associations

Individual Name: Mr. Paul Bomgardner

Location State: VA Country: US

View the Interpretation Document

Response text:

August 6, 1999


Mr. Paul Bomgardner                 Ref. No. 99-0096
Director, Hazardous Materials Policy
American Trucking Associations
2200 Mill Road
Alexandria, VA 22314-4677

Dear Mr. Bomgardner:

This is in response to your letter dated April 8, 1999, regarding the placement of an U.S. Environmental Protection Agency (EPA) waste code in shipping descriptions for hazardous wastes. Specifically, you ask if a materials EPA waste code can be placed between the shipping name and hazard class.

Section 172.202 (d) authorizes the placement of technical and chemical group names between the proper shipping name and hazard class.  It is the opinion of this office, that the hazardous waste code designated by the EPA for a material may be placed, on shipping papers, between the proper shipping tame and hazard class.  However, except for a material described as “Hazardous waste, liquid or solid, n.o.s”, an EPA hazardous waste code cannot be used to satisfy the requirement to place the technical name of the hazardous material in association with the basic description. (See § 172.203 (k).

I hope this satisfies your request.



Thomas G. Allan
Acting Director
Office of Hazardous Materials Standards



Regulation Sections

Section Subject
172.202 Description of hazardous material on shipping papers