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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #12-0122 ([Ohio Transportation Department] [Mr. Tom Forbes])

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

Interpretation Response Details

Response Publish Date:

Company Name: Ohio Transportation Department

Individual Name: Mr. Tom Forbes

Location State: OH Country: US

View the Interpretation Document

Response text:

August 6, 2012



Mr. Tom Forbes
Public Utilities Commission of Ohio
Transportation Department
180 East Broad Street
Columbus, Ohio 43215

Reference No.: 12-0122

Dear Mr. Forbes:

This responds to your May 23, 2012 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to reportable quantities (RQ) of hazardous materials. You state that you ship 24 one-pound pouches of Calcium Hypochlorite as a consumer commodity. You ask whether the amount of Calcium Hypochlorite in each individual pouch or the amount contained in the entire outer packaging is to be used in determining whether a RQ is met.
As prescribed in § 171.8, a hazardous substance is defined as a substance listed in Appendix A of § 172.101 and in a quantity, in one package, which equals or exceeds the RQ listed in Appendix A to § 172.101. A package or outside package is also defined as a packaging plus its contents. Further, a combination package is defined as one or more inner packagings secured in a non-bulk outer packaging. Based on the information, pictures, and supporting information provided in your letter, it is the opinion of this Office that the pouches of Calcium Hypochlorite are inner packagings of a combination package thus making the entire package subject to the RQ for Calcium Hypochlorite.

I hope this satisfies your inquiry. Please contact us if we can be of further assistance.



T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

171.8, 172.101

Regulation Sections

Section Subject
171.8 Definitions and abbreviations
172.101 Purpose and use of hazardous materials table