Gregory Sutherland - Comment

I see no listing of how the following section on Waste Exceptions is going to be treated? 49 CFR173.29 (b) Notwithstanding the requirements of paragraph (a) of this section, an empty packaging is not subject to any other requirements of this subchapter if it conforms to the following provisions: (b)(2)(iv) Contains only the residue of-- (b)(2)(iv)(A) An ORM-D material; or Will this now be converted to a Limited Quantity designation? The same exception needs to be retained for the disposal of small quantities of waste. This is a widely used exception as the EPA has a 3% residue limit on small containes that are considered a Hazwaste.