（Question on RQ rules for shipment of dangerous goods to USA.）
Q.
In making an application of loading USA bound hazardous material on ocean vessel, we received a query from the shipping company whether our shipment falls under the RQ rule. Please give us advice on how to respond to this query along with the rules of RQ. The item in question is UN1315 XYLENE Class 4.1 PG II. (31 Oct 20)
A.
When shipping dangerous goods to USA, we need to follow the RQ rule given in the 49CFR/, When shipping a certain quantity, you will be subjected to the Reportable Quantity (RQ) rule, and must insert the letters “RQ” on the Dangerous Goods Declaration and mark it on the outer surface of the package adjacent to the Proper Shipping Name. This rule is written in the US State Variation USG-04.
Referring to Table 1 of Appendix A of 49CFR 172.101, Xylene is listed for a RQ value of 100lbs (45.4 kg). However, you state UN1325 which is not Class 4.1 Xylene. Checking IMDG and IATA DGR, both regulations state UN1325 is not Class 4.1 Xylene but it is Flammable liquid, organic, n.o.s. Class 3 PG II or PG III. Checking Xylene in IMDG and in IATA DGR, I find it is UN1307 Xylenes Class 3 PG II or PG III. It is not Class 4.1. I wonder what are you trying to ship. Please double check your shipment.
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