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Interpretation Response #21-0027

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

Interpretation Response Details

Response Publish Date: 07-20-2021
Company Name: ACTenviro    Individual Name: Aaron Hayward
Location state: WA    Country: US

View the Interpretation Document

Response text:

July 20, 2021

Mr. Aaron Hayward
Account Manager
24602 Pacific Hwy S
Kent, WA 98032

Reference No. 21-0027

Dear Mr. Hayward:

This letter is in response to your March 10, 2021, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the description of limited quantities of waste materials on a waste manifest. In your email, you note that § 173.12(h)(1) states that the word "waste"—in association with the proper shipping name—is not required on individual packages and that § 173.12(h)(3) specifies that the outside of the shrink-wrap or stretch-wrap must be marked on opposite sides with "Waste, Limited Quantity." Specifically, you ask what the preferred method is to identify the number of packages on a pallet when preparing your Uniform Hazardous Waste Manifest (UHWM).

As provided by § 172.205(h), a hazardous waste manifest (i.e., a UHWM) required by 40 CFR Part 262, and containing the information required by Subpart C of Part 172, may be used as a shipping paper. In addition, § 172.202(a)(7) requires that the number and type of packages must be indicated, if not listed, on a shipping paper. Consistent with this requirement, the instructions for the UHWM require that the number and type of containers for each waste be entered in Block 10 “Containers (Number and Type)” of the UHWM. Therefore, the number of packages shrink wrapped on the pallet(s) must be included in Block 10 of the UHWM.

You may also choose to provide an additional notation of the number of pallet(s) in your shipment in Block 14 "Special Handling Instructions and Additional Information” of the UHWM—thereby communicating the number of shrink-wrapped waste pallet(s) that are being transported.

I hope this information is helpful. Please contact us if we can be of further assistance.


T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

173.12(h)(1), 173.12(h)(3), 172.202(a)(7), 172.205(h)

Regulation Sections

Section Subject
§ 172.205 Hazardous waste manifest