RQ, Waste and Marine Pollutant on a shipping paper
Three notations modify a basic description, and each has a trigger. "RQ" applies when a package contains a reportable quantity of a CERCLA hazardous substance — appendix A to 172.101 lists the thresholds, e.g. 1,000 lb for sulfuric acid. When the quantity in one package meets or exceeds the listed RQ, you add "RQ" to the description (172.203(c)). This tool stores the thresholds and flags RQ automatically when your entered quantity crosses one.
"Waste" applies to a hazardous waste — a material subject to the EPA manifest. The word "Waste" precedes the proper shipping name, e.g. "Waste, UN1993, Flammable liquid, n.o.s. (...)". "Marine Pollutant" applies to materials listed in appendix B to 172.101 (or meeting its criteria) and is shown as a notation associated with the description (172.203(l)).
Because these change the legally required text of the description, the tool treats them as explicit options and places each in the correct position: "Waste" and "RQ" as prefixes, "Marine Pollutant" as a suffix.
Open the generator — free, no upload
Applying the modifiers
- Check the RQ threshold (appendix A); add "RQ" when a package meets or exceeds it.
- Add "Waste" before the proper shipping name for an EPA hazardous waste.
- Add "Marine Pollutant" for appendix B materials or those meeting the criteria.
- Let the tool position each notation — it will not let you misorder them.
Questions
How do I know my RQ threshold?
It's listed in appendix A to 49 CFR 172.101 for each hazardous substance. This tool carries thresholds for the substances in its table and flags RQ when your entered quantity meets one.
Is RQ based on the whole shipment or one package?
On the quantity in a single package. Splitting a reportable quantity across packages does not avoid the RQ requirement if any one package meets the threshold.
Does "Marine Pollutant" matter for a highway shipment?
It can. Marine pollutant provisions primarily concern vessel transport, but the notation and related requirements can apply to ground shipments in bulk or those destined for export, so the option is available here.