Question on February 13, 2018:
Daniel –
Is clothing (scrubs) contaminated with friable asbestos dust and fibers (< 1 pound of asbestos per package) being transported to a laundry facility using in commerce roadways regulated by DOT as a hazardous material and thus subject to the applicable packaging, marking, labeling, placarding and shipping paper requirements? If so would the following be an appropriate proper shipping name?
“NA2212, Asbestos, PG III, 9 (mixture: clothing contaminated with friable asbestos)”
My reply that same day:![Shipping description for non-friable asbestos]()
Thank you for contacting me. Please see below.
- You are correct that friable asbestos is a hazardous material when transported in commerce.
- The shipping description is as follows: NA2212, Asbestos, 9, PG III. (Please note the sequence differs from what you have above.
- “(mixture: clothing contaminated with friable asbestos)” is not required but is permitted.
- If it is less than a pound of asbestos in each packaging it is not a reportable quantity (RQ) of a hazardous substance. More than a pound per package is subject to additional regulation. However, if unable to differentiate between the clothes and the asbestos, it will be necessary to consider the weight of the asbestos-contaminated clothing toward the 1 pound threshold.
- Read: Is asbestos waste a hazardous waste? A hazardous material?
- Read: The Government Employee Exemption (I included this because the person’s email address indicated a government agency).
I hope this helps. Please contact me with any other questions.
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Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail International and Domestic Daniels Training Services, Inc. 815.821.1550 |
That did it!
Thanks Daniel