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Interpretation Response #01-0170 ([ADCOM Express, Inc.] [Mr. Bradford A. Gagnon])

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

Interpretation Response Details

Response Publish Date:

Company Name: ADCOM Express, Inc.

Individual Name: Mr. Bradford A. Gagnon

Location State: CA Country: US

View the Interpretation Document

Response text:

August 13, 2001


Mr. Bradford A. Gagnon                       Ref. No. 01-0170
ADCOM Express, Inc.
2462-C South Santa Fe
Vista, CA 92084-8002

Dear Mr. Gagnon:

This is in response to your July 5, 2001 letter and subsequent phone conversations with Michael Johnsen of my staff regarding the determination of when a hazardous material is a hazardous substance under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).

In a conversation with Mr. Johnsen on July 31, 2001, many of the questions raised in your letter were addressed, but your question regarding how to determine the reportable quantity (RQ) of a mixture that is identified by more than one EPA waste code still required a response.

Enclosed is a February 26, 1998 letter from our office which provides that if you know the constituent and exact concentration of a waste stream, then the RQ amount for that constituent shall be used.  If the constituent or concentration is not known, then the RQ for that waste must be used to determine the RQ.  For a mixture that is identified by two or more EPA waste codes, the RQ amounts for each waste must be identified and determined by the amount of each waste code contained in the mixture.  In addition you would also need to meet the concentration limits found in the definition of “hazardous substance” in § 171.8.

I hope this satisfies your request.



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



Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table