Interpretation Response #99-0314 ([Safety-Kleen Chemical Services, Inc.] [Ms. Jean M. Soltys])
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 Chemical Services, Inc.
Individual Name: Ms. Jean M. Soltys
Location State: MA Country: US
View the Interpretation Document
Response text:
March 28, 2000
Ms. Jean M. Soltys Ref. No: 99-0314
Environmental Manager
Safety-Kleen Chemical Services, Inc.
221 Sutton Street
North Andover, MA 01845
Dear Ms. Soltys:
This is in response to your letter of November 12, 1999, requesting clarification of the notification requirements of § 178.2 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You ask whether your company may retain copies of written notification in electronic format. In addition you ask whether your company is required to provided notification in a situation where you provide a packaging to a customer but your company actually closes the packaging for your customer.
You may retain written notification in electronic format provided you are able to make such notification available for inspection by a representative of the Department. The written notification must identify all the requirements of Part 178 that have not been met at time of transfer, and any closure information necessary to properly close the packaging. Therefore, if your company provides a packaging to a customer and your company's employee takes responsibility for closing the packaging, there are no notification requirements necessary. However, your company must have a copy of the closure instructions and your employee must be trained in the proper closure requirements.
I hope this information is helpful.
Sincerely,
Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards
178.2