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printreg, February, 2003
How to Properly Name Hazardous Waste

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From: Debra Jacobson ( djacobson@istc.illinois.edu)
Date: Tue, 11 Feb 2003 08:38:39

Although EPA regulates the use of the hazardous waste manifest used for shipping waste off-site, the U.S. Department of Transportation influences a number of issues related to the shipment of the waste including labeling of containers (i.e. flammable, corrosive), roads the waste can be transported on, placarding of the vehicle, and the name of the waste on the manifest/shipping papers as well as on the hazardous waste label affixed to the container. DOT requirements affect the name of the waste since it is classified as a "hazardous material" as well as a waste. The following is a summary of the DOT requirements which impact naming the hazardous waste.
Debra Jacobson


49 CFR 172.202 How to Describe Hazardous Materials on Shipping Papers

According to 49 CFR 172.202, a hazardous material must be described in a specific sequence without any additional interspersed information. The basic description of a hazardous material must include the following information in this order:
1. Proper shipping name from Column 2 of the Hazardous Materials Table (HMT, 49 CFR 172.101)
2. The hazard class or division from Column 3 of the HMT
3. The UN or NA identification number from Column 4 of the HMT
4. The packing group, in Roman numerals, from Column 5 of the HMT

An example of a correct basic description is: Gasoline, 3, UN 1203, PGII

According to 49 CFR 172.202, the following additional information is required in association with the basic description.
- The total quantity of the material covered by one description must be shown before or after, or both before and after, the basic shipping description.
- You may enter the type of packaging and destination marks before or after the basic description. DOT allows the use of standard abbreviations to express units of measure and types of packaging.
- Technical or chemical names are must be added when the entry for the hazardous material on the Hazardous Materials Table (49 CFR 172.101) has a "G" in Column 1.

Technical or chemical names may be entered in parentheses between the proper shipping name and hazard class of the basic shipping description, or following the basic description. You can use an appropriate modifier such as "contains" or "containing," or the percentage of the technical constituent.

Additional description requirements are outlined in 49 CFR 172.203 for certain hazardous materials shipments, including those related to the identification of marine pollutants, hazardous substances, poisons, and limited quantities. It is important to provide the additional descriptions required by the regulations along with the basic description outlined above.

Source: "reg of the day" listserv operated by Tammy Silverthorne @ the Environmental Resource Center

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