DOT Shipping Description Determination

Answer to Question 1 - Yes - It is in the 172.101 Hazardous Materials Table

Answer to Question 2 - Yes - It is in the Appendix Table 1, Hazardous Substances - Reportable Quantities Table

3. Now it a bit tricky. The question is: Does the package contain more than the reportable quantity amount of any substance in the hazardous substance table? If the package is a mixture (not one pure chemical compound) , does it contains more than the corresponding rq amount for any of the substances in the table?

Yes - This package contains more than the RQ amount (for mixtures, the concentration times the amount of mixture is greater than the RQ: x% times Y total pounds of material > RQ)

No - Either the total weight of the package contents is less than the RQ, or for mixtures, no components concentration times the package contents weight exceeds it's corresponding RQ

Explanation: The question really is, if ALL of the contents of this package leaked, would any hazardous substance listed in Table 1 be released in a quantity greater than its corresponding RQ? Obviously, for pure compounds, this is easy. But for mixtures, you have to calculate the weight of the individual hazardous components from their concentration and the weight of the total package contents.

Examples: Acetone has an RQ of 5,000 pounds; so only if your package holds more than 5,000 pounds (not gallons) of acetone would you answer yes. On the other hand, if you have a 55 gallon drum of paint, you woulkd have to know what hazardous constituents are present in the paint (look at the MSDS - material safety data sheet - which the paint manufacturer or distributer must provide you upon request). So, paint often contains xylene, which has an RQ of 1000 pounds and MEK which has an RQ of 5,000 pounds. Since a drum of paint wouldn't ever weigh more than 600 pounds, the answer is no. Some RQ's are as low as 1 pound, so check every constituent!

Reference: 49 CFR 171.102, Table 1; 172.203(c)

Additional information: If you do not have a copy of the DOT HM Tables click here to download a current copy (free) in Adobe PDF format.