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Interpretation Response #99-0167 ([Virginia Polytechnic Institute and State University] [Mr. Frank Imperatore])

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

Interpretation Response Details

Response Publish Date:

Company Name: Virginia Polytechnic Institute and State University

Individual Name: Mr. Frank Imperatore

Location State: VA Country: US

View the Interpretation Document

Response text:

August 7, 1999


Mr. Frank Imperatore                    Ref. No. 99-0167
Environmental Health and Safety Services
Virginia Polytechnic Institute and State University
 459 Tech Center Drive
Blacksburg, VA 24061

Dear Mr. Imperatore:

This is in response to your letter dated June 24, 1999, and subsequent telephone conversation with a member of my staff, regarding the proper packaging and shipping descriptions for waste cyanides and brucine under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).

Virginia Tech generates the following materials as waste for off site shipment: sodium cyanide; potassium cyanide; and brucine.

Under § 173.22, it is the shipper's responsibility to properly classify and describe a hazardous material in accordance with Parts 172 and 173.  Such determinations are not required to be verified by this Office.  In the scenario you present in your letter you describe all three hazardous materials with one proper shipping name, “Waste toxic solids, inorganic, N.O.S., 6.1, UN3288, PG I, (Sodium cyanide, Brucine, Potassium cyanide) .”  This description is incorrect.  The proper description of each hazardous material offered for transportation is required on the shipping paper (§ 172.200 (a) ) . In addition, a non-bulk packaging must be marked with the proper shipping name and identification number for each hazardous material in the packaging (§ 172.301). For example, a combination packaging containing inner containers of waste sodium cyanide, waste potassium cyanide and waste brucine would be described as follows:

Waste, sodium cyanide, 6.1, UN1588, PG I

Waste, potassium cyanide, 6.1, UN1680, PG I

Waste, brucine, 6.1, UN1570,  PG I

You are correct in your understanding that materials meeting the definition of Division 6.1, Packing Group I may not be packaged in lab packs (§ 173.12(b)(3)). Materials shipped in non-bulk packagings under the shipping names “Waste, sodium cyanide,” “'Waste, potassium cyanide” and 'Waste, brucine,” that are Packing Group I materials, must be packaged in accordance with § 173.211. An outer packaging may contain more than one hazardous material; however, it is the responsibility of the person offering a hazardous material for transportation to ensure that the requirements in 173.21, 173.24 and 173.24a are met.

I hope this satisfies your request.



Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.22 Shipper's responsibility