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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #99-0323 ([Piper, Marbury, Rudnick, & Wolfe, L.LP.] [Mr. Steven J. Groseclose])

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

Interpretation Response Details

Response Publish Date:

Company Name: Piper, Marbury, Rudnick, & Wolfe, L.LP.

Individual Name: Mr. Steven J. Groseclose

Location State: DC Country: US

View the Interpretation Document

Response text:

January 27, 2000


Mr. Steven J. Groseclose                   Ref. No. 99-0323
Piper, Marbury, Rudnick,
    & Wolfe, L.LP.
1200 19th  Street, NW
Washington, D.C. 20036-2412

Dear Mr. Groseclose:

This is in reference to your letter concerning highway shipments of articles containing polychlorinated
biPhenyls (PCBs) and mercury containing fluorescent lighting tubes under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).

You are correct in your understanding that a transformer containing a PCB laden dielectric fluid is only regulated by highway as a hazardous substance if the one pound reportable quantity (RQ) of PCBs is met or exceeded in one package at a concentration by weight of 20 ppm or greater.  If you meet or exceed the RQ per package and are transporting PCBs by highway, the packing group for this shipment would read  “PG III”  instead of  “PG II” as specified in § 172.101 (f).

Additionally, you requested confirmation that mercury-containing lamps which are considered universal
wastes by the Environmental Protection Agency (EPA) are not considered hazardous wastes by the
Department of Transportation and ask whether these lamps are regulated under the HMR.  Universal wastes do not meet the definition of a hazardous waste in § 171.8 because universal wastes are not subject to EPA's hazardous waste manifest requirements.  Mercury is only regulated in air and water shipments and mercury contained in manufactured articles is only regulated in air shipments.  Thus, if your highway shipment of mercury-containing lamps does not meet the definition of a hazardous substance or any other hazard, then it is not regulated by the HMR.

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