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Q&A: Transportation of Transformer Oil with PCBs

Q&A: Transportation of Transformer Oil with PCBs

A question from a past Onsite Training customer (4.20.15):


I have a question. We need to ship out a sample approximately a quart of transformer oil which contains 550 ppm PCBs. If the material is below the RQ value (see enclosed letter), what type of labeling is required, or does it since it’s below the RQ value?

My reply that same day:

I will take a look at it and get back to you.

Turns out he didn’t need the information after all (4.20.15):

No problem, I found out that my lab can do the testing, so I don’t have to ship the material out.

Pre-printed label used to identify a PCB WasteDid that stop me?  No!  (April 22, 2015):

Not sure if you require this information any more, but here goes:

A PCB oil is only a hazardous materials subject to USDOT regulations in transportation if there is 1 lb or greater of PCBs in a single packaging. 1 quart at 550 ppm would be well below 1 lb of PCBs, therefore it is not a HazMat when transported.

A PCB oil of this concentration would be subject to TSCA regulations of which I am not very familiar.

I hope this helps.


Wait, how did you know that?

First of all, let’s look at the entry for PCBs in the Hazardous Materials Table (49 CFR 172.101):

Entry for PCBs in Hazardous Materials Table


So, you’d think that PCBs are a hazardous material when offered for transportation and that my response to my customer was wrong.  But…you’d say that before looking up the meaning of Special Provision 140 in column 7, which reads:

This material is regulated only when it meets the defining criteria for a hazardous substance or a marine pollutant…

So, is it a marine pollutant?

PCBs are identified on the marine pollutant list at Appendix B to 49 CFR 172.101, but to be regulated as a marine pollutant it must also offered for transportation by vessel or transported in a bulk packaging, neither of which is the case here.

Is it a hazardous substance?

No, because a Reportable Quantity of PCBs is 1 pound, as I described in my email of 4.22.15, the volume of oil and concentration of PCBs put it well below this amount.

Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail

International and Domestic

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There you have it.  While the amount and concentration of PCB oil considered for transportation was not a hazardous material, a different packaging and volume might be.  Be sure to carefully research the Hazardous Material Regulations of the PHMSA/USDOT before you send that sample to the lab.

Or, contact me to answer your questions or to provide HazMat Employee training.