Interpretation Response #09-0307
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
January 28, 2010
Mr. James V. Lovitz
PSC Environmental Services, LLC
6405 Thornridge Dr.
Avon, IN 46123
Ref. No. 09-0307
Dear Mr. Lovitz:
This responds to your letter requesting clarification of the criteria used to select the appropriate proper shipping name or names (PSN) for multiple compatible waste hazardous materials of various hazard classes and divisions contained within one outer package under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You ask whether one generic PSN from the § 172.101 Hazardous Materials Table may be used to describe all the different materials contained in the package or if the PSN must first be determined based on the Precedence of Hazard Table in § 173.2a(b).
According to you letter, the waste materials are compatible and comingling of the materials in transportation would not result in a dangerous evolution of heat, flammable or poisonous gases or vapors or corrosive materials (§ 173.21 (e)).
You may package inner containers of different compatible hazard classes in the same outer packaging. The materials must be described separately using the PSN, UN identification number, and hazard class for each material contained in the outer packaging. Thus, the outer package must display the PSN, identification number and hazard label, as appropriate, for each hazardous material contained therein. See §§ 172.301 and 172.404. Additionally, all descriptions must be described in the same manner on a shipping paper, if one is required.
I trust this satisfies your inquiry. Please contact us if we can be of further assistance.
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
|§ 173.21||Forbidden materials and packages|