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Interpretation Response #10-0084 ([Commercial Chemical] [Mr. David L. Turnage])

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

Interpretation Response Details

Response Publish Date:

Company Name: Commercial Chemical

Individual Name: Mr. David L. Turnage

Location State: TX Country: US

View the Interpretation Document

Response text:

May 11, 2010




Mr. David L. Turnage

Commercial Chemical

1707 Townhurst

Houston, TX 77043

Ref. No. 10-0084

Dear Mr. Turnage:

This responds to your April 16, 2010 request for clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask when must the letters "RQ" be included on a shipping paper.

In your letter, you state that you are getting conflicting guidance for showing the letters "RQ" on your shipping paper for the following chemicals:

Hypochlorite solution, 8, UN 1791, PG II

Trichloroisocyanuric acid-dry, 5.1, UN 2468,

You further state that, for the above materials, you do not include the letters "RQ" on the shipping paper because the materials are not listed in the Appendix A to §172.101. The letters "RQ" must be included on the shipping paper if the material is listed in the Appendix A of 172.101, and is packaged in a quantity, in one package which equals or exceeds the reportable quantity listed in the Appendix. Therefore, for the materials listed above, the letters "RQ" are not required to be included on the shipping paper because your materials are not listed in the Appendix A to §172.101.

I hope this answers your inquiry. If you need additional assistance, please contact this Office.


Charles E. Betts

Chief, Standards Development

Office of Hazardous Materials Standards


Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table