Classification of Metallic Billets

This is in response to your letters of April 12, 1993, requesting a determination of whether heavy metallic billets containing cadmium copper alloys and beryllium copper alloys are regulated as hazardous materials under this Department's Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). The billets are from 6 to 12 inches in diameter and 5 to 22 feet in length, although they might be cut into 3 to 5 foot lengths for shipment, and contain .5% to 1.5% cadmium or beryllium. I apologize for the delay in response and hope it has not caused any inconvenience.

Based on the form of these materials and the data you submitted, we have determined that the billets as described are not considered hazardous materials under the HMR. This determination is based on the provisions of § 173.132(c). Shippers and carriers of non-hazardous materials are not required to register under § 107.601.