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Interpretation Response #13-0223 ([Mr. William Briner])

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

Interpretation Response Details

Response Publish Date:

Company Name:

Individual Name: Mr. William Briner

Location State: MO Country: US

View the Interpretation Document

Response text:

December 19, 2013

Mr. William Briner
670 Grey Oaks Drive
Weldon Springs, MO 63304

Reference No.: 13-0223

Dear Mr. Briner:

This responds to your November 5, 2013 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 50 pound multi-wall paper bags of Sodium phosphate, dibasic.  You note that Sodium phosphate, dibasic does not meet the definition of hazardous material for Classes 1 through 8, but that it is listed in Appendix A of § 172.101 with an RQ of 5000 pounds.   You seek confirmation that Sodium phosphate, dibasic shipped in 50 pound bags is not regulated as a hazardous substance even if 100 or more bags of this material are offered for transportation in a single shipment.  

You are correct.  The definition for a hazardous substance does not include the aggregate of packages in a single shipment. 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.  

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


Duane Pfund
International Standards Coordinator
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