Interpretation Response #05-0107 ([Reactives Management Corporation] [Ms. Cherie Walton])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Reactives Management Corporation
Individual Name: Ms. Cherie Walton
Location State: VA Country: US
View the Interpretation Document
Response text:
May 17, 2005
Ms. Cherie Walton Reference No. 05-0107
Reactives Management Corporation
1025 Executive Blvd., Suite 101
Chesapeake, VA 23320
Dear Ms. Walton:
This is in response to your April 13, 2005 letter requesting clarification regarding the shipping paper requirements for hazardous substances and explosives as specifie4 under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your questions are paraphrased and answered as follows:
Q1. Section 172.201(a)(1)(iii) specifies that the letters “RQ” may replace the “X” in the “HM” column. Is the use of the letters “RQ” in “HM” column optional in all circumstances?
Al. Yes. Section 172.202(c)(2) allows for the letters “RQ” to be placed either before or after the basic description.
Q2. Do the letters “RQ” have to be included with the basic shipping description if material does not exceed the reportable quantity?
A2. No. The letters “RQ” may only be entered on the shipping paper if a material meets the definition of a hazardous substance under § 171.8.
Q3. Section 172.202(a)(5)(iii) specifies that the net explosive mass must be indicated on a shipping paper to describe the total quantity for a Class 1 material. Is it acceptable to indicate the gross mass of an explosive article under the “quantity” column and specify the net explosive mass under the “additional description” portion of the shipping paper?
A3. No. The net explosive mass should be specified under the “quantity” column as detailed in § 172.202(c).
I hope this information is helpful.
Sincerely,
Hattie L. Mitchell, Chief
Regulatory Review and Reinvention
Office of Hazardous Materials Standards
172.210, 172.203
Regulation Sections
| Section | Subject |
|---|---|
| 172.203 | Additional description requirements |