Commercial Chemical — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation 1200 New Jersey Ave, SE Pipeline and Hazardous Materials Washington, D.C. 20590 Safety Administration ~:AY 11 2010 Mr. David L. Turnage Commercial Chemical 1707 Townhurst Houston, TX 77043 Ref. No. 10-0084 Dear Mr. Turnage: This responds to your April 16, 2010 request for clarification ofthe Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask when must the letters "RQ" be included on a shipping paper. In your letter, you state that you are getting conflicting guidance for showing the letters "RQ" on your shipping paper for the following chemicals: Hypochlorite solution, 8, UN 1791, PG II Trichloroisocyanuric acid-dry, 5.1, UN 2468, You further state that, for the above materials, you do not include the letters "RQ" on the shipping paper because the materials are not listed in the Appendix A to § 172.1 0 1. The letters "RQ" must be included on the shipping paper if the material is listed in the Appendix A of 172.101, and is packaged in a quantity, in one package which equals or exceeds the reportable quantity listed in the Appendix. Therefore, for the materials listed above, the letters ··RQ" are not required to be included on the shipping paper because your materials are not listed in the Appendix A to §172.1 01. I hope this answers your inquiry. If you need additional assistance, please contact this Office. Sincerel" ~f~ Charles E. Betts hief, Standards Development Office of Hazardous Materials Standards#

Page 2Drakeford, Carol From: INFOCNTR (PHMSA) ~hiIf)D.()ti (. e(S Sent: Friday, April 16, 2010 8:28 AM rI To: Drakeford, Carolyn (PHMSA) 0- ()() cgt Cc: wilson, leandrew (PHMSA) Subject: FW: Feedback: General Questions/Comments Regarding the PHMSA Enforcement Pro ram Carolyn, See below. This man is requesting a formal written letter of interpretation. Thanks, Rob -----Original Message----From: PHMSA-Feedback [mailto:PHMSA-Feedback] Sent: Thursday, April 15, 2010 4:14 PM To: HM-Enforcement (PHMSA); PHMSA Webmaster Subject: Feedback: General Questions/Comments Regarding the PHMSA Enforcement Program In need of written clarification please of the following; We keep running into a conflict with showing or not showing "RQ" on our bill of ladings for two of our chemicals. This is how we list these two: 1. HYPOCHLORITE SOLUTION, 8, UN1791, PG II 2. TRICHLOROISOCYANURIC ACID-DRY, 5.1, UN2468, PG II We do not show RQ for these items because these proper shipping names are not listed in the RQ section of the CFR. We made these changes last year at the insistance of a local DOT enforcement officer but now we are getting hassel because we are not showing RQ. Please clarify by return email, letter or fax. Thanks Name: David L. Turnage Organization: Commercial Chemical dba: Poolsure Email: dturnage@poolsure.com Address: 1707 Townhurst City: Houston Zip Code: 77043 Phone: 800-858-7665 ext. 107 FAX: 800-909-3962 1#