Yes. Though special provision 156 in column 7 of the Hazardous Materials Table excepts from regulation asbestos that is immersed or fixed in a natural or artificial binder material, i.e. non-friable, the shipper may still classify a non-friable asbestos and offer it for transportation as a Hazardous Material (HazMat). [LOI 03-0262]
Special Provision 156:
Asbestos that is immersed or fixed in a natural or artificial binder material, such as cement, plastic, asphalt, resins or mineral ore, or contained in manufactured products is not subject to the requirements of this subchapter.
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Interestingly, asbestos is identified as a hazardous substance in Table 1 to Appendix A of the Hazardous Materials Table. It has a low RQ (Reportable Quantity) of 1 lb (0.454 kg). However, a note to the entry reads as follows:
The RQ for asbestos is limited to friable forms only.
So, it is acceptable to ship a non-friable asbestos as a hazardous material even though it – because of special provision 156 – is not subject to the regulations, a shipper will not be able to identify it as a Reportable Quantity of a hazardous substance.