A shipping paper lists a material at a quantity equal to its EPA-assigned Reportable Quantity (RQ) from Appendix A to Sec. 172.101. A separate shipment consists of used solvent being sent for disposal under an EPA manifest. How are these two materials classified under 49 CFR 171.8?

Question

Accepted Answer

The first is a hazardous substance (listed at/above its RQ); the second is a hazardous waste (subject to EPA manifest requirements)

Answer

Both are classified as hazardous waste, since both involve EPA regulatory tracking

Answer

The first is a hazardous waste; the second is a hazardous substance

Answer

Neither is a distinct regulatory category unless it is also a listed marine pollutant