Interpretation Response #13-0234 ([Strem Chemcials, Inc.] [Mr. Jason M. Stevens])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Strem Chemcials, Inc.
Individual Name: Mr. Jason M. Stevens
Location State: MA Country: US
View the Interpretation Document
Response text:
February 11, 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 CFR Parts 171-180) relating to the description of hazardous substances on shipping papers, and the placement of the 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,
Duane A. Pfund
International Standards Coordinator
Standards and Rulemaking Division
172.203, 172.702
Regulation Sections
| Section | Subject |
|---|---|
| 172.203 | Additional description requirements |