One phrase is used by two different agencies with different meanings.
a. EPA Reportable Quantities: Reportable quantities for Extremely Hazardous Substances are listed at 40 CFR 355.33, Appendices A and B. Reportable quantities of CERCLA Hazardous Substances are listed in Table 302.4 of 40 CFR 302.4. Release of a reportable quantity within any 24-hour period triggers the emergency release notification requirement. For further light reading, compare and contrast RQ with Threshold Planning Quantities (TPQ). They are not the same, trigger different compliance / response / planning programs, but are both derived from Superfund.
b. DOT Reportable Quantities: The abbreviation (RQ) must appear on shipping papers when specified amounts of specified materials are transported in one container (box, drum, tote bin, tank truck, rail car). DOT RQs are listed at 49 CFR 172.101. As you noted the RQ for chloroform is 10 pounds (EPA and DOT), so the abbreviation RQ must appear on the shipping papers when more than 10 pounds of chloroform is shipped in one container.
Depending on your role(s) in environmental health and safety, you may have to deal with RQs on shipping papers and hazardous waste manifests; RQs from storage spills (not necessarily transportation related) and the TPQ that Frankie cited in the SARA Title III reports typically due in March.
And there will be no jokes about minding you Ps and Qs
George C. Walton, CHMM
Reactives Management Corporation
1025 Executive Blvd., Suite 101
Chesapeake, VA 23320
From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**MED.CORNELL.EDU] On Behalf Of Frankie Wood-Black
Sent: Tuesday, July 8, 2014 8:57 AM
Subject: Re: [DCHAS-L] Reportable Quantities?
Storage requirements are under SARA 311 and 312. There is typically a March 1 inventory update to the local emergency planning committee, the state emergency planning committee and the house local fire department. Want people tend to forget is that there is also a reporting requirement when you exceed a threshold quantity of a chemical not on you inventory.
On Jul 7, 2014 3:16 PM, "Murphy, Dr. Ruth Ann" <rmurphy**At_Symbol_Here**umhb.edu> wrote:
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.
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
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