By Andy Altemos, Senior Technical Advisor    September, 2007

Packaging Exceptions for Waste Materials

Sections 173.12(c) and 173.28;
letter dated July 17, 2007
to Clifford W. Lester,
Huntsman

This letter is worthy of particular note in that it confirms that the packaging exceptions for “waste materials” in § 173.12(c) of the Hazardous Materials Regulations (HMR) apply to all wastes when the materials are transported for “disposal or recovery” (subject to the conditions and limitations in that paragraph) - and not just to “hazardous wastes” subject to the EPA Hazardous Waste Manifest requirements. This is, perhaps, implicit by the absence of the word “hazardous” modifying the word “waste” where it appears in this section. Nevertheless, this confirmation by DOT of the broader intent of these provisions is quite helpful.

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