Mr. William Briner — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration DEC 1 9 2013 William Briner 670 Grey Oaks Drive Weldon Springs, MO 63304 1200 New Jersey Avenue, SE Washington, D.C. 20590 Reference No.: 13-0223 Dear Mr. Briner: This responds to your November 5, 2013 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to reportable quantities (RQ) of hazardous materials. You state that you ship 50 pound multi -wall paper bags of Sodium phosphate, dibasic. You note that Sodium phosphate, dibasic does not meet the definition of hazardous material for Classes 1 through 8, but that it is listed in Appendix A of§ 172.10 I with an RQ of 5000 pounds. You seek confirmation that Sodium phosphate, dibasic shipped in 50 pound bags is not regulated as a hazardous substance even if 100 or more bags of this material are offered for transportation in a single shipment. You are correct. The definition for a hazardous substance does not include the aggregate of packages in a single shipment. As prescribed in § I7I.8, a hazardous substance is defined as a substance listed in Appendix A of§ I72.I 0 I and in a quantity, in one package, which equals or exceeds the RQ listed in Appendix A to § I72.I 0 I. I hope this satisfies your inquiry. Please contact us if we can be of further assistance. Sincerely, .... ualt c /f .··~·~r·?/G ... ( ·~ ' - I'' ; Duane Pfund International Standards Coordinator Standards and Rulemaking Division#

Page 2November 5, 2013 William J. Briner 670 Grey Oaks Drive Weldon Spring, MO 63304 Standards and Rulemaking Division Pipeline and Hazardous Materials Safety Administration, Attn: PHH-10 U.S. Department of Transportation, East Building 1200 New Jersey Avenue, S.E. Washington, D.C. 20590-0001 Request for Interpretation Dear Sir or Madame: I am writing to request an interpretation concerning the shipment of multi wall paper bags each containing 50 pounds of disodium phosphate, anhydrous (CAS# 7558-79-4). Other synonyms for disodium phosphate, anhydrous are disodium phosphate and sodium phosphate, dibasic. Sodium phosphate, dibasic is listed in 49 CFR Appendix A to 172.101 as a hazardous substance with a reportable quantity of 5000 pounds. Disodium phosphate, anhydrous does not meet the definition of hazard classes 1 through 8. Based upon the above, please confirm that disodium phosphate, anhydrous in 50 pound multiwall paper bags is not regulated as a hazardous material under the DOT Hazardous Materials Regulations, even if 100 or more of these bags are offered for transportation in a single shipment. Sincerely, 0>-~ct, ~ William J. Briner#