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    SUBJECT: "RQ" Clarification for DOT Shipping Paper Entries

    QUESTION:

     A customer has ten drums of a waste solvent in which three of the drums have a reportable quantity

    (RQ) of a certain solvent constituent and the other seven do not. The DOT basic description for the ten drums is identical except for the "RQ" designator required for the three drums containing the RQ constituent. Must the customer describe the seven non-RQ drums and the three RQ drums as separate line entries on the manifest, or can all drums be described one the same line entry using a basic description containing the "RQ" descriptor?


    ANSWER: A review of 49 CFR 172.203(c) concerning additional descriptions for reportable quantities does not address the above scenario specifically as do no other DOT regulations. However, a DOT letter dated March 4, 1994, states emphatically that all drums can be described on the same line entry.

    "The answer is yes. The packages may be described under one line item entry using the RQ designation, as long as some of the packages contain an RQ."

    Therefore, the customer can ship the ten drums under one line entry using the RQ designator as long the basic description is identical for the non-RQ and the RQ wastestreams, and as long as at least some of the drums contain a reportable quantity.

    In the event of an accident, an emergency responder reviewing the manifest would note that the drums are described as containing a reportable quantity. Then to identify the specific RQ drums the emergency responder would look for the "RQ" mark required to be clearly displayed on the appropriate drums.

    SUMMARY:

     Multiple drums of non-RQ and RQ materials can be described as a single line entry if:         		DOT basic description is identical for both the non-RQ and RQ materials, except for the "RQ" designator, and;
    long as some of the drums contain a reportable quantity.
    If you would a copy of 49 CFR 172.203(c) and the DOT March 4, 1994 letter follow below:

    Regulation:

    49 CFR 172.203 Additional description requirements.

    (c) Hazardous substances.

    (c)(1) Except for Class 7 (radioactive) materials described in accordance with paragraph (d) of this section, if the proper shipping name for a material that is a hazardous substance does not identify the hazardous substance by name, the name of the hazardous substance must be entered in parentheses in association with the basic description. If the material contains two or more hazardous substances, at least two hazardous substances, including the two with the lowest reportable quantities (RQs), must be identified. For a hazardous waste, the waste code (e.g., D001), if appropriate, may be used to identify the hazardous substance.

    (c)(2) The letters "RQ" shall be entered on the shipping paper either before or after, the basic description required by CFR#172.202 for each hazardous substance (see definition in CFR#171.8 of this subchapter). For example: "RQ, Allyl alcohol, 6.1, UN 1098, I"; or "Environmentally hazardous substance, solid, n.o.s., 9, UN 3077, III, RQ (Adipic acid)".

    US Department of Transportation Research and Special Programs Administration

    MAR 4, 1994

    Mr. Denis M. Padovani
    Transportation Compliance Manager
    Safety-Kleen Corporation
    1000 North Randall Road
    Elgin, Illinois 60123-7857

    Dear Mr. Padovani:

    This is in response to your letter of September 27, 1993, requesting clarification on shipping paper requirements for drums containing waste petroleum naphtha, when some drums contain a reportable quantity and others do not.

    Specifically, you ask whether all of the drums can be described using one line entry on the shipping paper. Presently, you are using two separate line entries with the shipping descriptions being identical (i.e., Waste, Combustible liquid, n.o.s. (petroleum naphtha), NA1993, III), except for the "RQ" designator.

    The answer is yes. The packages may be described under one line entry using the RQ designation, as long as some of the packages contain an RQ.

    I hope this information is helpful.

    Sincerely,

    Edward T. MazzulloDirector, Office of Hazardous Materials Standards
    DISCLAIMER - "WEEKLY TRAINING" is a voluntary non-governmental guidance document only. While every effort is made to present accurate information, your conditions may vary and this document is not intended to render legal or technical advice for site-specific applications. Use as general guidance only and call EHSO to obtain professional assistance for your specific applications.

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