Strem Chemcials, Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, D.C. 20590 FEB 1 1 2014 Mr. Jason M. Stevens Warehouse Manager Strem Chemicals, Inc. 7 Mulliken Way Newburyport, MA 01950 Ref. No.: 13-0234 Dear Mr. Stevens: This is in response to your letter dated December 2, 2013, requesting clarification of the Hazardous Materials Regulations (HMR; 49 CPR Parts 171-180) relating to the description of hazardous substances on shipping papers, and the placement ofthe letters "RQ". You provide an example shipping paper which shows the "RQ" notation after the basic description, but not in a location immediately before or after the basic description. You note that it is your understanding that the "RQ" must be immediately before or after the basic description. You ask for confirmation that the "RQ" notation as shown in your example shipping paper would not be in compliance with § 172.203(c)(2). Section 172.203( c )(2) requires the letters "RQ" to be entered on the shipping paper either before or after the basic description required by§ 172.702 for each hazardous substance, and provides examples of acceptable methods of noting the letters "RQ" on shipping papers. The two examples given are not the only acceptable places to note the letters "RQ". The "RQ" component may follow the basic description of the hazardous material in any reasonable format, provided it is clearly part of the entry. It is the opinion of this office that the indication "RQ (Benzene)" as illustrated in the example provided appears after the basic description as required by the HMR. The example shipping paper provided only shows one entry for a hazardous material. If there are multiple consecutive entries, care should be taken to ensure it is clear which entry the "RQ" notation is associated with. I trust this information is helpful. If you have further questions, please do not hesitate to contact this office. Sincerely, :~ AvrJi~(~ · !' t~~ ....-'\,}, f) r tv.r ' ' Duane A. Pfund International Standards Coordinator Standards and Rulemaking Division#

Page 2December 2, 2013 U.S. DOT PHMSA Office of Hazardous Materials Standards Attn: PHH-10 East Building 1200 New Jersey Avenue, SE. Washington, DC 20590-0001 Dear Sirs, I am writing to you for clarification regarding additional description requirements for shipping papers as specified in 49 CFR 172.203(c)(2). When applicable, the letters "RQ" must be entered on the shipping paper either before or after the required basic description. It is my understanding that the basic description of a hazardous material includes the Identification Number, the Proper Shipping Name, Hazard Class/Division followed by subsidiary Hazard Class(es)/Division(s) as appropriate, and Packing Group when applicable. Consistent with your examples provided in the HMR, this requirement appears to leave the shipper with only two clear options when entering the letters "RQ", before or after the basic description. Despite this, I have encountered an influential training agency teaching its members and participants something quite different. Namely, it is being taught that the "RQ'' can be inserted following other information required on shipping papers, despite the fact that the information that it follows is not part of the basic description. Below, I have created an example of a shipping paper prepared for air transportation which illustrates acceptable information being conveyed to trainees:#

Page 3It is my opinion that this example does not meet the requirements as set forth by 49 CFR 172.203(c)(2) therefore it could not possibly be compliant. It is my hope that you will confirm that my understanding is correct. If confirmed, I will forward your interpretation along to the training agency in hopes that they will adjust their teachings and avoid misleading their students. I appreciate your clarification in the matter. Sincerely, j 1r'\ / t/, . f"/ )~~ /l /Jason M. Stevens (/ Warehouse Manager Strem Chemicals, Inc. 7 Mulliken Way Newburyport MA 01950 /~,<;"')@ shefl'l.coM#