Interpretation Response #01-0210 ([Shell Chemicals] [Mr. David Mashinski])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date: 01/18/2002

Company Name: Shell Chemicals

Individual Name: Mr. David Mashinski

Location State: TX Country: US

View the Interpretation Document

Response text:

January 18, 2002

Mr. David Mashinski                            Reference. No. 01-0210
Shell Chemicals
P.O. Box 2463
Houston, TX 77252

Dear Mr. Mashinski:

This is in response to your August 1,  2001 letter requesting clarification of the shipping paper requirements under the Hazardous Material Regulations (HMR; 49 CFR Parts 171-180) pertaining to the shipping description 'Residue: Last Contained, Flammable liquids, n.o.s., 3, UN1993, III, RQ (Ethylbenzene)." I apologize for any inconvenience that the delay in responding may have caused you.

Specifically, you ask whether the letters "RQ" must be removed from the basic shipping description for the return trip of a tank car.  You state that prior to the return trip, the tank car will be unloaded and, therefore, will no longer contain the reportable quantity of a hazardous substance.

The answer is no.  In accordance with § 172.203(e)(2), the description on the shipping paper for a tank car containing the residue of a hazardous material must include the phrase “Residue: Last Contained * * *” before the basic description.  If, when fully loaded, the correct shipping description for the material in the tank car required the letters “RQ” to be included, the letters “RQ” are not required to be removed from the shipping paper description when the residue in the tank car no longer meets the definition of a hazardous substance.

I hope this information is helpful.  Please contact this office if you need additional assistance.

Sincerely,

John A. Gale
Transportation Regulations Specialist
Office of Hazardous Materials Standards

172.203(e)(2)

Regulation Sections