From: Steve Bonnell <Steve.Bonnell**At_Symbol_Here**TEVAPHARM.COM>
Subject: Re: [DCHAS-L] Reportable Quantities?
Date: Mon, 7 Jul 2014 17:11:21 -0400
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: 4196E763C4DDD3458D198257BE665C6480B2A18EFF**At_Symbol_Here**USCCR02.NA.Teva.Corp
In-Reply-To <4D0A3882C09D2E42BE7C6B7265CB0D5F012306237E**At_Symbol_Here**AVATAR.umhb.edu>


There are two locations and definitions for RQs:

 

1.       40 CFR 302.4: TABLE 302.4—LIST OF HAZARDOUS SUBSTANCES AND REPORTABLE QUANTITIES

RQ therein being defined as:

“Reportable quantity (‘‘RQ’’) means that quantity, as set forth in this part, the release of which requires notification pursuant to this part;…”

 

2.       49 CFR 172.101: TABLE 1 TO APPENDIX A—HAZARDOUS SUBSTANCES OTHER THAN RADIONUCLIDES

Where, if you are shipping a hazardous material you will see that shipping the RQ of that substance in a single container causes that shipment to be a “Hazardous Substance”. On the shippers’ declaration, you would list that material with “RQ” annotated in the HM column.

 

Note: You would report storage of a “Threshold Quantity” of a hazardous chemical for EPCRA reporting requirements under SARA Title III. The threshold quantity for chloroform is 10,000 lbs. You can confirm that by searching the “Consolidated List lf Lists” available for download at http://www2.epa.gov/epcra/consolidated-list-lists. The big table is presented in two sort orders—first by CAS then by IUPAC or common name.

 

Best regards,

 

JSBonnell

 

 

From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**MED.CORNELL.EDU] On Behalf Of Murphy, Dr. Ruth Ann (External)
Sent: Monday, July 07, 2014 3:57 PM
To: DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU
Subject: [DCHAS-L] Reportable Quantities?

 

 

Good Afternoon,

 

Do "Reportable Quantities," RQ's, refer to storage or release?

 

In other words the RQ for chloroform is listed as 10 pounds and the RQ for silver nitrate as one pound.  Is there any requirement that storage of this amount of these chemicals in Texas be reported, and if so, to whom?  I can understand reporting release of these chemicals in the stated amounts, but reporting mere storage would require a lot of paperwork.

 

Thank you.

 

Ruth Ann

 

 

Ruth Ann Murphy, Ph.D.

Professor of Chemistry

Chairperson, Department of Chemistry, Environmental Science and Geology

Co-Chairperson, Health Professions Advisory Committee

Amy LeVesconte Professorship of Chemistry

JAMP Faculty Director

The University of Mary Hardin-Baylor

900 College Street

Belton, TX  76513-2599

Phone 254.295.4542

 

 

 

 

 

 

 

 

 

 

 


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