Interpretation Response #13-0223 ([Mr. William Briner])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name:
Individual Name: Mr. William Briner
Location State: MO Country: US
View the Interpretation Document
Response text:
December 19, 2013
Mr. William Briner
670 Grey Oaks Drive
Weldon Springs, MO 63304
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 § 172.101 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 § 171.8, a hazardous substance is defined as a substance listed in Appendix A of § 172.101 and in a quantity, in one package, which equals or exceeds the RQ listed in Appendix A to § 172.101.
I hope this satisfies your inquiry. Please contact us if we can be of further assistance.
Sincerely,
Duane Pfund
International Standards Coordinator
Standards and Rulemaking Division
171.8, 172.101