2.2 Reportable Quantities, WASTE, Technical Names, and the Shipper's Certification

2.2 Reportable Quantities, WASTE, Technical Names, and the Shipper's Certification

Additional Required Elements on Shipping Papers

Beyond the four-part basic description, federal and state regulations mandate several critical document notations:

Total Quantity and Packaging Types

• The shipping paper must specify the number and type of packages (e.g., "12 drums", "4 cylinders", "1 cargo tank", "2 intermediate bulk containers (IBCs)").
• It must indicate the total net or gross quantity by volume or mass (e.g., "500 gal", "2,400 lbs", "1,500 kg").

Reportable Quantity ("RQ")

• Under federal environmental statutes (CERCLA) and 49 CFR 172.101 Appendix A (List of Hazardous Substances and Reportable Quantities), hazardous substances are assigned a specific discharge threshold known as a Reportable Quantity.
• If a single commercial package contains an amount of a listed hazardous substance that equals or exceeds its assigned RQ threshold, the letters "RQ" must be displayed on the shipping paper.
• Permissible Placement: The letters "RQ" must be entered either immediately before or immediately after the basic description.
  • Example A: RQ, UN1090, Acetone, 3, PG II
  • Example B: UN1090, Acetone, 3, PG II, RQ
• If an accidental discharge of an RQ package occurs, the motor carrier must immediately notify the federal National Response Center (NRC).

EPA Hazardous Waste and the Uniform Manifest

• Hazardous wastes regulated under EPA rules (40 CFR Part 262) must be accompanied by an EPA Form 8700-22 Uniform Hazardous Waste Manifest.
• The word "WASTE" must precede the proper shipping name in the basic description unless the word waste is already included in the official HMT name.
  • Example: UN1170, WASTE Ethanol, 3, PG II
• The manifest tracks the waste from the initial generator (shipper), through every commercial transporter (drivers/carriers), to the designated Treatment, Storage, and Disposal Facility (TSDF). Each party must sign and date the manifest upon transferring custody.

Technical Names for Generic and N.O.S. Descriptions

• Many chemicals are shipped under generic or "Not Otherwise Specified" (n.o.s.) proper shipping names (e.g., Flammable liquids, n.o.s. or Corrosive liquids, n.o.s.).
• When Column 1 of the Hazardous Materials Table displays the letter "G", the shipper must identify the specific recognized chemical or technical name of the hazard-causing constituent in parentheses immediately following or adjacent to the proper shipping name (49 CFR 172.203(k)).
  • Example: UN1993, Flammable liquids, n.o.s. (contains Toluene and Methanol), 3, PG II

Toxic Inhalation Hazard (TIH) / Poison Inhalation Hazard (PIH)

• Materials that present severe inhalation risks must be explicitly designated with the words "Toxic Inhalation Hazard" or "Inhalation Hazard", accompanied by the assigned Hazard Zone (Zone A, Zone B, Zone C, or Zone D).
  • Example: UN1052, Hydrogen fluoride, anhydrous, 8 (6.1), PG I, Hazard Zone C, Toxic Inhalation Hazard
• Even when transported in small quantities, TIH Zone A and Zone B materials trigger special placarding and routing mandates.

Shipper's Certification Statement

• Every shipping paper originating from a non-bulk offeror must include a signed certification certifying that the materials are prepared in strict compliance with federal law (49 CFR 172.204).
• Standard authorized wording: "This is to certify that the above-named materials are properly classified, described, packaged, marked, and labeled, and are in proper condition for transportation according to the applicable regulations of the Department of Transportation."
• Must be signed manually or electronically by the shipper's authorized representative. A shipping paper missing this certification is legally invalid, and drivers must refuse to accept the cargo.

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Comparison Table: Compliant vs. Non-Compliant Shipping Descriptions

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Commercial Driving Scenario: Roadside Inspection on I-95 in Virginia

Roadside Case Study: A commercial driver operating a dry van is pulled into the Virginia State Police Motor Carrier Safety Inspection facility on Interstate 95 near Carson, Virginia, for a CVSA Level II driver and documentation inspection.

The driver presents the bill of lading to the State Police Trooper. The manifest lists ten 55-gallon drums of industrial paint solvent formatted as follows: "5,000 lbs, Flammable Liquid, UN1993, Class 3, PG II, Paint Solvent"

The inspecting trooper informs the driver that the shipping paper contains multiple serious regulatory violations:

1. The basic description violates the mandatory ISHP sequence by placing quantity and shipping name ahead of the UN number.
2. The proper shipping name "Flammable Liquid" is invalid because the official HMT name is "Flammable liquids, n.o.s."
3. The generic description lacks the mandatory chemical constituent technical name in parentheses (e.g., contains Xylene and Toluene).

The trooper issues a formal safety violation citation to the motor carrier and places the driver out of service until a corrected, compliant shipping paper is transmitted and certified by the shipper.

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Common Exam Traps & Pitfalls

• Trap: The Legacy "SHPI" Sequence
  • The Exam Trick: An exam question presents an answer choice with the Proper Shipping Name first (e.g., "Gasoline, 3, UN1203, PG II") and claims it is acceptable.
  • The Legal Reality: Years ago, federal regulations permitted the shipping name first. However, federal law amended 49 CFR 172.202 to mandate the international ISHP sequence (Identification Number first). Any test option showing the name or class ahead of the UN/NA number is incorrect.
• Trap: Reportable Quantity Placement Rules
  • The Exam Trick: A question asserts that "RQ" can be placed anywhere on the shipping paper, such as in the special handling remarks at the bottom of the page.
  • The Legal Reality: Under 49 CFR 172.203(c), the letters "RQ" must appear immediately before or immediately after the basic description. Stashing "RQ" in a distant comments box is a regulatory violation.
• Trap: Using Trade Names as Proper Shipping Names
  • The Exam Trick: A scenario describes shipping "Super Solvent Cleaner #4" or "Bleach-All".
  • The Legal Reality: Commercial brand names and trademarks cannot substitute for official proper shipping names from Column 2 of the Hazardous Materials Table.