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Interpretation Response #15-0048 ([Oak Harbor Freight Lines, Inc.] [Mr. Tom Mueller])

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

Interpretation Response Details

Response Publish Date:

Company Name: Oak Harbor Freight Lines, Inc.

Individual Name: Mr. Tom Mueller

Location State: NV Country: US

View the Interpretation Document

Response text:

June 25, 2015

Mr. Tom Mueller
Manager, Safety and Compliance
Oak Harbor Freight Lines, Inc.
8960 Terabyte Drive
Reno, NV 89521-5932

Reference No. 15-0048

Dear Mr. Mueller:

This is in response to your January 22, 2015 e-mail requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to hazardous substances. In your letter, you state your company recently shipped a cylinder containing 25 milliliters of "UN 1605 Ethylene Dibromide, 6.1 (poisonous), Packaging Group (PG) I" inside a fiberboard box. You also state the completed package complies with Special Permit DOT-SP 9168 and weighs 2 pounds. We have paraphrased your questions and answered them in the order you provided.

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).

I hope this satisfies your request.


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

172.101, 171.8, 172.202(a)(5), 172.202(a)(7), 172.202(c), 172.201(a)(4), 172.202(a)

Regulation Sections

Section Subject
171.8 Definitions and abbreviations
172.101 Purpose and use of hazardous materials table
172.201 Preparation and retention of shipping papers
172.202 Description of hazardous material on shipping papers