SUBJECT: "RQ" Clarification for DOT Shipping Paper Entries

QUESTION:  A customer has ten drums of a waste solvent in which three of the drums have a reportable quantity

(RQ) of a certain solvent constituent and the other seven do not. The DOT basic description for the ten drums is identical except for the "RQ" designator required for the three drums containing the RQ constituent. Must the customer describe the seven non-RQ drums and the three RQ drums as separate line entries on the manifest, or can all drums be described one the same line entry using a basic description containing the "RQ" descriptor?

ANSWER: A review of 49 CFR 172.203(c) concerning additional descriptions for reportable quantities does not address the above scenario specifically as do no other DOT regulations. However, a DOT letter dated March 4, 1994, states emphatically that all drums can be described on the same line entry.

"The answer is yes. The packages may be described under one line item entry using the RQ designation, as long as some of the packages contain an RQ."

Therefore, the customer can ship the ten drums under one line entry using the RQ designator as long the basic description is identical for the non-RQ and the RQ wastestreams, and as long as at least some of the drums contain a reportable quantity.

In the event of an accident, an emergency responder reviewing the manifest would note that the drums are described as containing a reportable quantity. Then to identify the specific RQ drums the emergency responder would look for the "RQ" mark required to be clearly displayed on the appropriate drums.

SUMMARY: Multiple drums of non-RQ and RQ materials can be described as a single line entry if: