When to Indicate RQ for Hazmat Shipments

When a hazardous material is accidentally released from a motor vehicle, rail car, aircraft, or ship, the release is more than a “transportation problem.” The hazardous material can enter the environment through the air, water, or soil, cause a public health hazard, and necessitate environmental cleanup.

While US DOT’s Hazardous Materials Regulations (HMR) apply to the transportation of hazmat, certain 49 CFR requirements address potential environmental impacts of hazmat releases.

One intersection between US DOT and environmental regulations is the rules for hazardous substances in transportation, including the requirement to mark a Reportable Quantity or “RQ” on packages and hazmat shipping papers in certain situations.

This blog answers 4 frequently asked questions about RQs:

• What does “RQ” mean?
• What is a hazardous substance under DOT regulations?
• When and how to indicate RQ on non-bulk packages
• When and how to indicate RQ on shipping papers

The reportable quantity or “RQ” for a hazardous substance is the amount of the material that, if released, requires immediate reporting to the National Response Center (NRC).

Does Every Hazardous Material Have an RQ?

No. A DOT hazardous material has an RQ associated with it only if it is a hazardous substance. DOT lists hazardous substances in Appendix A to the 49 CFR 172.101 Hazmat Table. The appendix lists each hazardous substance with its corresponding reportable quantity in pounds and kilograms.

The RQ for a material can be as low as one pound or as high as 5,000 pounds. The graver the threat to human health and the environment, the lower the material’s RQ.

The List of Hazardous Substances Comes from the EPA

DOT gets its list of hazardous substances from a major environmental program—the Comprehensive Environmental Response, Compensation, and Liability Act or CERCLA (sometimes called Superfund). In CERCLA, the hazardous substance list is found in 40 CFR 302.4.

The definition of a hazardous substance in CERCLA references other environmental statutes including the Clean Air Act, Clean Water Act, RCRA hazardous waste regulations, and the Toxic Substances Control Act (TSCA).

When to Include RQ on Shipping Papers and Packages

To ensure compliance with the regulation to indicate RQ when required, shippers should ask themselves three questions before offering any hazardous materials for transportation:

1. Is my material listed in Appendix A as a hazardous substance?
2. What is the RQ for my hazardous substance?
3. Does my package contain a reportable quantity of the hazardous substance?

When a single hazardous materials package—a box, an IBC, a tank, etc.—contains a reportable quantity of a hazardous substance, the letters RQ must appear on the hazmat shipping papers, either before or after the hazmat basic description [49 CFR 172.203(c)(2)].

When a single non-bulk package contains a reportable quantity of a hazardous substance, the shipper must mark the outer package with the letters “RQ” in association with the Proper Shipping Name [49 CFR 172.324(b)].

Adding Additional Information

In some cases, the Proper Shipping Name (PSN) of a hazardous material may not clearly identify the hazardous substance it contains. For both shipping paper and package markings that indicate the letters “RQ,” the DOT requires additional information be added to adequately identify the hazardous substance. [See 49 CFR 172.324(a)]

For example, a mixture containing several flammable liquids including a quantity of the hazardous substance benzene equaling or exceeding its RQ may be named “Flammable Liquids, n.o.s.” Because the PSN does not include the word benzene, the chemical name must be added in parentheses after the PSN or at the end of the basic description, like this:

UN 1993, Flammable liquid, n.o.s. (benzene), 3, PG II RQ

OR

RQ UN 1993, Flammable liquid, n.o.s., 3, PG II (benzene)

By adding RQ to the shipping papers and packages (when required), shippers alert drivers and others in the supply chain handling the packages that a release from that package may require reporting to the NRC.

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