Interpretation Response #99-0060 ([Danzas S.P.A] [Mr. Carlo De Mercurio])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Danzas S.P.A
Individual Name: Mr. Carlo De Mercurio
Country: IT
View the Interpretation Document
Response text:
MAR 30, 1999
Mr. Carlo De Mercurio Ref. No 99-0060
Danzas Verona
Danzas S.P.A
Via Torricelli, 49
1-37136 Verona, Italy
Dear Mr. De Merdurio:
This is in response to your letter of February 19, 1999, regarding the Hazardous Material, Regulations (HMR; 49 CFR Parts 171-180). Specifically, you asked us to provide reportable quantity values (RQs) for a hazardous material described as "Environmentally hazardous substance, liquid, n.o.s, UN3082," that contains 2,3,5,6,6- tetrafloro behzyl trans 2,2,2 -dichlorovenyl and 3,3,dimethylcyclopropane carboxylate.
The HMR require the letters "RQ" to appear on is shipping paper if the haza dous material meets the definition of a hazardous substance (§ 172.20 (c) (2)). As defined in § 171.8, a hazardous substance is a material that is listed in Appendix A to 172.101, is in a package that meets or exceeds the RQ, and when in a mixture or solution, has a concentration by weight which equals or exceeds the concentration corresponding to the RQ of the material as listed in the table in § 171.8. A material must meet all of these requirements in order to be a hazardous substance. Appendix A lists hazardous substances by their chemical name or waste name, and lists each substance's corresponding RQ value in pounds or kilograms.
You should review Appendix A to determine if the chemicals in your customer's material have RQs. If the chemicals do not appear in Appendix A, then you need not mark RQ on your shipping paper. I have enclosed copies of appropriate parts of §§ 171.8, Appendix A to 172.101, and 172.203.
I hope this satisfies your request.
Sincerely,
John A. Gale
Transportation Regulations Specialist
Office of Hazardous Materials Standards,
Enclosures
173.203(c)