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Interpretation Response #13-0121 ([ClearEdge Power] [Mr. Ron Collins])

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

Interpretation Response Details

Response Publish Date:

Company Name: ClearEdge Power

Individual Name: Mr. Ron Collins

Location State: OR Country: US

View the Interpretation Document

Response text:

July 11, 2013


Mr. Ron Collins
Inventory Control Coordinator
ClearEdge Power
7175 NW Evergreen Parkway, Ste. 100
Hillsboro, OR  97124

Reference No.: 13-0121

Dear Mr. Collins:

This is in response to your May 29, 2013 email to the Standards and Rulemaking Division of the Office of Hazardous Materials Safety requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you ask if the determination as to whether or not your shipment meets or exceeds the reportable quantity listed in the appendix A to § 172.101 is based on the amount of hazardous materials, or on the total weight of your package.  You state that you offer hazardous materials under a special permit in a non-DOT specification closed bulk bin.  You also state the actual weight of the hazardous materials in the bulk bin is 29 pounds, and the metal assembly containing the material is 600 pounds.

The definition of a hazardous substance is found in § 171.8.  A hazardous substance (other than a radionuclide) is defined as a material, including its mixtures and solutions, that: (1) is listed in appendix A to § 172.101 of the HMR; (2) is in a quantity, in one package, which equals or exceeds its reportable quantity (RQ) listed in appendix A to 172.101 of the HMR; and (3) when in a mixture or solution, is in a concentration by weight which equals or exceeds the concentration corresponding to the RQ of the material, as shown in § 171.8.  The total amount of the material listed by name in appendix A to § 172.101 should be used to determine if your shipment meets or exceeds the reportable quantity shown in column two of the appendix.  From the information you provided, the weight you would use to make your hazardous substance determination would be 29 pounds.

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


Delmer Billings
Senior Regulatory Advisor
Standards and Rulemaking Division

172.101, 171.8

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table