Reactives Management Corporation — Hazardous Materials Safety Interpretation

Page 1U.S. Department 400 Seventh Street, S.W. of Transportation Washingion, D.C. 20590 Pipeline and Administration Hazardous Materials Safety MAY 17 2005 Ms. Cherie Walton Ref. No. 05-0107 Reactives Management Corporation 1025 Executive Blvd., Suite 101 Chesapeake, VA 23320 Dear Ms. Walton: paper requirements for hazardous substances and explosives as specified under the Hazardous This is in response to your April 13, 2005 letter requesting clarification regarding the shipping Materials Regulations (HMR; 49 CFR Parts 171-180). Your questions are paraphrased and answered as follows: Q1. Section 172.201(a)(1)(iii) specifies that the letters "RQ" may replace the "X" in the "HM" column. Is the use of the letters "RQ" in "HM" column optional in all circumstances? Al. Yes. Section 172.202(c)(2) allows for the letters "RQ" to be placed either before or after the basic clescription. Q2. Do the letters "RQ" have to be included with the basic shipping description if material does not exceed the reportable quantity? A2. No. 'The letters "RQ" may only be entered on the shipping paper if a material meets the definition of a hazardous substance under § 171.8. Q3. Section 172.202(a)(5)(iii) specifies that the net explosive mass must be indicated on a shipping paper to describe the total quantity for a Class 1 material. Is it acceptable to indicate the gross rnass of an explosive article under the "quantity" column and specify the net explosive mass under the "additional description" portion of the shipping paper? A3. No. 'The net explosive mass should be specified under the "quantity" column as detailed in § 172.202(c). I hope this information is helpful. Sincerely, Hothe z-michel Hattie L. Mitchell, Chief Office of Hazardous Materials Standards Regulatory Review and Reinvention 172.210 172•203 050107#

Page 2INFOCNTR <PHMSA> Satterthwaite From: Sent: reactives@earthlink.net Subject: To: INFOCNTR <PHMSA> Thursday, April 28, 2005 1:34 PM 5172203 Information Center Comments/Questions Shipping tapers Cherie walton (reactives@earthlink.net) on Thursday, April 28, Below is the result of your feedback form. It was submitted by 05-0107 at 13:34:19. Email: reactives@earthlink.net Name: Cherie Walton Category: Emergency Response Information (Sections 172.1 - 172.807) Organization: Reactives Management Corporation Street: 1025 Executive Blvd., Suite 101 City: Chesapeake State: Virginia Zip Code: 23320 Phone: 757-436-1033 Fax: 757-548-2308 Comments: RE: Shipping Papers: 172.210 and 172.203 required (if ever) to be placed in the column of the shipping paper captioned Please clarify the circumstances in which the letters "RQ" (rather than an "X") are che use of "R" in the "HM" column is optional in all circumstances. 172.201 (a) (iii) says the "X" may be replaced by "R", if appropriate. "May be..." implies 172.203 requires the letters "RQ" be entered on the shipping paper either before or after basic description, but that section doesn't address the "HM" column on the shipping Some examples: f, for example, you wanted to ship a mixed waste which contains less than the reportable Juantity of mercury (which is a hazardous substance with an RQ of 1 pound), would an "x' 'etters "RO" have to be in the basic description since you are shipping less than the ›r "RO" go in the "HM" column? If "RQ", is that required or optional? Also, do the reportable quantity of a hazardous substance? Another example: If you wanted to ship a mixed waste which contains more than the reportable quantity of mercury, would an "X" or chat required or optional? Could you put an "X" in the "HM" column if you wanted to? "RO" ao in the "HM" column? If "RQ", is we primarily ship articles, the mass of the materials is generally much higher than the lastly, referring to 172.202 (a) (5), "the quantity must be the net explosive mass". Since net explosive mass. "quantity" column, then put the net explosive mass under "additional description"? Is it acceptable to enter the mass of the materials in the Thank you. 1#