Q1. Is the weight of the packaging combined with the weight of the hazardous material within that packaging used to determine whether or not the hazardous material meets a reportable quantity?

A1. The answer is no. A hazardous substance is a material listed in Appendix A of § 172.101 that is in a quantity in one completed package that equals or exceeds the reportable quantity (RQ) for that material listed in Appendix A to § 172.101 and, when in a mixture or solution, satisfies the applicable criteria for "hazardous substances" as this term is defined in § 171.8.

Q2. Where on the shipping paper and in what format should the shipper describe the actual quantity of hazardous material within a package and that package's total weight?

A2. Section 172.202(a)(5) requires that--except for bulk packages, cylinders, and packages containing only hazardous material residue--the total quantity, including the unit of measurement of the hazardous materials covered by the description be included in the shipping papers. Total quantity may be entered as net weight, gross weight, capacity, or as otherwise appropriate. The number and type of packages (for example, "10 cylinders per box" and "5 fiberboard boxes") must also be indicated on a shipping paper either before or after the required basic description (see §§ 172.202(a)(7) and 172.202(c)). Certain information may be placed before the basic description, such as quantity shipped, the type of packaging and destination marks as prescribed in §§ 172.201(a)(4) and 172.202(c)). Otherwise, additional information must be entered on the shipping paper after the basic description prescribed in § 172.202(a).