Interpretation Response #17-0044
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
July 11, 2017
Mr. Jim O'Hara
Laidlaw Carriers Tank LP
605 Athlone Avenue
P.O. Box 1571
Woodstock, Ontario N4S-A7
Reference No. 17-0044
Dear Mr. O'Hara:
This letter is in response to your April 21, 2017, ema'il requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to shipping papers. You state your understanding that the HMR permit shipments under the guidelines of Transport Canada's Transportation of Dangerous Goods (TDG) Regulations, which do not require the letters "RQ" to be included on the shipping paper. You further ask whether the shipping paper for shipments made to or from Canada in compliance with the TDG Regulations must list an RQ.
The answer is yes. While § 171.12 of the HMR permits hazardous materials that are shipped to or from Canada to be offered for transportation in accordance with Transport Canada's TDG Regulations, § 171.23 imposes additional requirements for certain materials, which include hazardous substances. Specifically, § 171.23(b)(5) requires a material that meets the definition of a hazardous substance to conform to the shipping paper requirements in § 172.203(c), as well as the marking requirements in § 172.324. Therefore, when shipping a hazardous substance in the United States, the letters "RQ" must be entered on the shipping paper and the package in association with the proper shipping name for each hazardous substance in your shipment.
I hope this information is helpful. Please contact us if we can be of further assistance.
Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division
171.12, 171.23, 171.23(b)(5), 172.324, 172.203(c)
|§ 172.203||Additional description requirements|