Lab Pack Exception
Pipeline and Hazardous Materials Safety Administration · Sep 12, 2006 · Reference No. 06-0168
Interprets: 49 CFR § 173.12
Reggie’s quick take
A company that packs lab waste asked whether a lab pack holding two kinds of Division 4.1 flammable solids must be described by one of the named entries that include "organic" or "inorganic," or whether each material can get its own generic name. PHMSA says that for a lab pack under § 173.12(b), when no generic proper shipping name covers all the materials in the package, the shipper may use either the generic or the specific proper shipping name for each material inside it.
Written by AI (Claude) on Oct 22, 2026. Robots make mistakes and leave things out, so the letter below is what counts. Not legal advice.
This is in response to your June 26, 2006 letter concerning how to select the correct proper shipping name for a lab pack containing two types of Division 4.1 (flammable solid) materials under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). In your example, you state the outer package contains five bottles, three that contain organic compounds and two that contain inorganic metal powders. Because there is no generic flammable solid proper shipping name without the word "organic" or "inorganic' on the Hazardous Materials Table (HMT; § 172.101), you ask if you must choose one of these names to describe the lab pack or if a generic proper shipping name for each material must be used.
The lab pack exception in § 173.12(b) allows a shipper to use a generic proper shipping name in place of specific chemical names to represent two or more compatible waste materials of the same hazard class in the same outside packaging provided the items are packaged, described, and transported in accordance with this section. If an appropriate generic proper shipping name to describe all the materials within the package is not provided in the HMR, either the generic or specific proper shipping name for each material contained within the package may be used.
A letter of interpretation applies the regulations to the facts the requester described. It isn’t a regulation and isn’t legal advice. The agency’s copy.