Shipping Descriptions for Waste Materials
Pipeline and Hazardous Materials Safety Administration · Aug 27, 1999 · Reference No. 99-0167
Reggie’s quick take
Someone asked how to describe and package waste sodium cyanide, potassium cyanide and brucine for off-site shipment. The agency said a single shipping name listing all three is wrong. Each material needs its own proper shipping description on the shipping paper, and non-bulk packages must be marked with the name and ID number of each material inside. Because these are Packing Group I materials, they cannot go in lab packs, and they must be packaged under § 173.211. The shipper remains responsible for classification and description.
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 letter dated June 24, 1999, and subsequent telephone conversation with a member of my staff, regarding the proper packaging and shipping descriptions for waste cyanides and brucine under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).
Virginia Tech generates the following materials as waste for off site shipment: sodium cyanide; potassium cyanide; and brucine.
Under § 173.22, it is the shipper's responsibility to properly classify and describe a hazardous material in accordance with Parts 172 and 173. Such determinations are not required to be verified by this Office. In the scenario you present in your letter you describe all three hazardous materials with one proper shipping name, "Waste toxic solids, inorganic, N.O.S., 6.1, UN3288, PG I, (Sodium cyanide, Brucine, Potassium cyanide) ." This description is incorrect. The proper description of each hazardous material offered for transportation is required on the shipping paper (§ 172.200(a)). In addition, a non-bulk packaging must be marked with the proper shipping name and identification number for each hazardous material in the packaging (§ 172.301). For example, a combination packaging containing inner containers of waste sodium cyanide, waste potassium cyanide and waste brucine would be described as follows:
Waste, sodium cyanide, 6.1, UN1588, PG I
Waste, potassium cyanide, 6.1, UN1680, PG I
Waste, brucine, 6.1, UN1570, PG I
You are correct in your understanding that materials meeting the definition of Division 6.1, Packing Group I may not be packaged in lab packs (§ 173.12(b)(3)). Materials shipped in non-bulk packagings under the shipping names "Waste, sodium cyanide," "'Waste, potassium cyanide" and 'Waste, brucine," that are Packing Group I materials, must be packaged in accordance with § 173.211. An outer packaging may contain more than one hazardous material; however, it is the responsibility of the person offering a hazardous material for transportation to ensure that the requirements in 173.21, 173.24 and 173.24a are met.
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.