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Interpretation Response #15-0085 ([Transport Corp. of America] [Mr. Greg Payne])

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

Interpretation Response Details

Response Publish Date:

Company Name: Transport Corp. of America

Individual Name: Mr. Greg Payne

Location State: IA Country: US

View the Interpretation Document

Response text:

August 12, 2015

Mr. Greg Payney
Support Center Manger/ Field Support Specialist
Transport Corp. of America
2875 West Penn St.
North Liberty, IA 52317

Ref. No. 15-0085

Dear Mr. Payne:

This is in response to your May 1, 2015 e-mail request and subsequent telephone conversation with a member of my staff regarding requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to hazardous substances. You state that you received a violation for not indicating the letters RQ on the shipping paper for a shipment of UN 1760, Corrosive liquid, n.o.s (Phosphoric Acid, Hydrofluoric Acid) 8, PG II, 2 Drums, 1096 LBS. You ask if there is an HMR requirement for the shipper to include the weight or concentration range of each hazardous component of a mixture on shipping papers.

The answer to your question is no. There is no requirement for a shipper to indicate weights or concentration ranges for hazardous components of a mixture or solution. Section 172.203(c) prescribes the documentation requirements for materials that are hazardous substances. Based on the information provided, since the weight of the hydrofluoric acid in the mixture is below the 100 pound limit indicated in Appendix A to § 172.101, the letters "RQ" on the shipping paper would not be required for this hazardous material.

I trust this information is helpful. If you have further questions, please do not hesitate to contact this office.



Duane Pfund
International Standards Coordinator
Standards and Rulemaking Division

172.203(c), 172.101

Regulation Sections

Section Subject
172.101 Purpose and use of hazardous materials table
172.203 Additional description requirements