Lab packs for international shipment
Pipeline and Hazardous Materials Safety Administration · Mar 4, 2008 · Reference No. 07-0144
Interprets: 49 CFR § 173.12
Reggie’s quick take
A waste company asked whether lab packs of waste containing aniline or phenol can use a generic shipping name, even though these materials carry a "+" sign in column one of the §172.101 table. PHMSA said yes. Under §173.12(b), these waste materials may be packed with other compatible waste in the same hazard class, in the same outside packaging, and described by one generic shipping name. The generic name must be marked on the outside of the lab pack. This reverses two earlier letters that had barred the "+" materials from generic names.
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 responds to your July 13, 2007 letter requesting clarification of the proper shipping description for lab packs under §173.12(b) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you request reconsideration of information provided in a letter issued by this office in 2002 and ask how to describe certain hazardous materials that are identified with a "+" sign in column one of the §172.101 Hazardous Materials Table (HMT).
Section 173.12(b) permits a shipper to use non-specification packaging and, for compatible materials in the same hazard class, a generic shipping name rather than specific chemical names for the materials packed in a lab pack. Section 172.101(b)(1) states, in part, "the plus (+) sign fixes the proper shipping name, hazard class, and packing group for that entry without regard to whether the material meets the definition of that class, packing group or any other hazard class designation." In two previous letters issued by this office (Ref. Nos. 99-0145 and 02-0014), we indicated materials identified with a "+" sign in column one of the HMT are not eligible for the exception allowing for use of a generic proper shipping name, on the basis that the "+" sign "fixes" the proper shipping name.
Based on your inquiry and the issues you raise, we have reevaluated the aforementioned interpretations. Section 172.101(b)(1) is intended to ensure that certain materials that are known to present hazards in transportation but that do not meet specific hazard class definitions are appropriately described and classed. However, §173.12 provides exceptions to this provision if the lab packs of waste materials meet the requirements of and the packages are prepared in accordance with §173.12. Therefore, it is our determination that waste materials containing Aniline and/or Phenol are eligible for the §173.12(b) exceptions and may be packaged in lab packs with other compatible waste hazardous materials in the same hazard class in the same outside packaging and described using a generic proper shipping name. Multiple shipping names are not required. The generic proper shipping name must be marked on the outside packaging of the lab pack. Requirements for lab packs are provided in §173.12(b).
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.