Table of Contents
- What Does RQ Stand For?
- Do All Hazardous Materials Have a Required Quantity?
- How Are DOT Reportable Quantities Determined?
- When to Indicate RQ for Hazmat Shipments
- The Marking and Labeling Requirements for Hazardous Materials
- Browse Our Hazmat Shipping Training Courses Today
When accidentally released, hazardous materials pose several health and environmental challenges. As a result, federal agencies have set regulations to control the usage and transportation of these dangerous substances. These guidelines and rules make it crucial to understand how to determine reportable quantities for hazmat shipments.
What Does RQ Stand For?
RQ stands for “reportable quantity.” The reportable quantity of a hazardous substance is the amount of that substance that has to be released before the Environmental Protection Agency (EPA) requires notification to the National Response Center (NRC). The quantities of the substance are based on volumes, and the reporting threshold differs depending on the substance.
For example, while a discharge of 5,000 pounds of benzoic acid must be reported to the EPA, a release of even one pound of arsenic pentoxide is reportable. Generally, the lower the material’s RQ, the more serious the threat to human health and the environment.
Containers of hazardous materials that reach their reportable quantity levels must be labeled to contain the abbreviation “RQ.” The exact reportable volume quantities are determined by federal, state and agency regulations.
What Is Considered a Hazardous Substance?
A hazardous substance is a chemical listed by its waste code or chemical name in Appendix A to the 172.101 of the Hazardous Materials Table and collected in one container in an amount that equals or exceeds the list provided.
Under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), also referred to as Superfund, the definition of “hazardous substance” references several environmental authorities, including:
- Section 112 of the Clean Air Act (CAA) — “CAA Hazardous Air Pollutants”
- Section 311 of the Clean Water Act (CWA) — “CWA Hazardous Substances”
- Section 307(a) of the CWA — “CWA Toxic Pollutants”
- Section 3001 of the Resource Conservation and Recovery Act (RCRA) — “RCRA Hazardous Wastes”
- Section 7 of the Toxic Substance Control Act (TSCA) — currently has no designated substances
Section 102(a) of CERCLA also gives the EPA the authority to designate additional hazardous substances to those listed above.
So, along with the EPA, other regulators of dangerous substances are the Department of Transportation (DOT) and the Occupational Safety and Health Administration (OSHA). The EPA regulates environmental discharges and guides the reporting of releases to the NRC, the DOT regulates transportation releases and OSHA protects workers from the release of hazardous substances.
What Is the National Response Center?
The NRC is the central communication point for reports about the release of hazardous substances in the United States. Any release of dangerous materials, whether chemical, oil, biological, radiological or etiological — meaning disease-causing — must be reported to the NRC. The NRC also receives reports of fatalities resulting from transporting hazardous materials. Then, it gathers detailed information regarding the incident and transmits them to the proper federal authorities.
Do All Hazardous Materials Have a Required Quantity?
The simple answer is no. Hazardous materials with associated RQ labels are those considered and listed as such under the 49 Code of Federal Regulations (CFR) 172.101 Hazmat Table. This table lists the hazardous substances with their corresponding RQ in pounds and kilograms.
The 49 CFR covers requirements for labeling, marking, placards, training shipping papers, emergency response and performance-oriented packaging standards. Handlers of hazardous waste or materials, shippers, carriers or freight forwarders must comply with these regulations.
How Are DOT Reportable Quantities Determined?
The DOT reportable quantity list requires shippers, carriers or freight forwards to consult Appendix A and determine whether a container equals or exceeds the RQ amount. The list caters to marking shipping containers and paperwork.
When to Indicate RQ for Hazmat Shipments
Shippers should consider three vital questions to know when to indicate RQ for hazmat shipments:
- Does Appendix A list the material as hazardous?
- What is the dangerous substance’s required RQ?
- Does the package provide a reportable quantity of the hazardous substance?
When a single package of hazardous materials such as a tank, an intermediate bulk container (IBC) or a box contains a dangerous substance reportable quantity, the letters “RQ” should appear on the hazmat shipping papers before or after the basic hazmat description. For a single non-bulk package containing a hazardous substance, mark the outer package with the letters “RQ” in association with the proper shipping name.
The Marking and Labeling Requirements for Hazardous Materials
Packages of hazardous materials are communicated through marking and labeling. These regulations are outlined in subparts D and E of the hazardous materials regulations.
Marking and labeling may be the first indicators that the package contains the shipment of dangerous materials. Markings ensure the proper handling of shipments to prevent accidents, spills and exposure. Labels usually communicate the hazards associated with the package — but there’s more:
Marking is the descriptive name, instruction, caution, identification number, weight, specification, UN marks or a combination of these elements required on the outer packaging of dangerous goods or hazardous materials. There are different requirements for marking, including:
- The marking must be in English.
- It must be durable and affixed to or printed on the surface of the packaging or a label, sign or tag.
- It must be unobscured by attachments and labels.
- It must be displayed on a background of sharply contrasting colors.
- It must be located away from other markings, such as advertisements, that could substantially reduce its effectiveness.
There are specialized markings, such as marking for liquid hazardous goods. There are also specific marking requirements for poisonous and dangerous goods, radioactive materials and dangerous goods in limited quantities.
Labels identify the specific primary and subsidiary hazards that the materials in a dangerous goods package pose. They rely on specific codes, colors and pictograms to clearly and instantly identify the type of materials in the package.
Regulations require labels to be printed on or affixed to the surface of the containment device of the package containing the hazardous material. However, it should not be at the bottom. Also, if the package dimensions allow, the label must be on the same surface of the package and near the proper shipping name marking.
Browse Our Hazmat Shipping Training Courses Today
Federal, state and local regulators aim to protect the environment and public health. That’s why comprehensive standards have been provided for the shipment of hazardous substances. Understanding all aspects of the reportable quantity requirements for dangerous goods helps you stay compliant.
Hazmat School offers hazardous materials and OSHA safety courses across various industries. Our online 49 CFR DOT hazmat shipping training courses are designed to help you and your team gain the required knowledge and certifications conveniently and affordably. Browse our course list or contact us with any questions!