Capacitors Containing Polychlorinated Biphenyls (PCBs)
Pipeline and Hazardous Materials Safety Administration · Jan 13, 1988 · Reference No. 88-0002
Reggie’s quick take
A company asked how to describe capacitors containing PCBs on a shipping manifest when they pack 10 to 20 capacitors into a plastic bag and then place 15 to 20 of those bags in a 55-gallon drum. The agency said the description depends on how much PCB is in each drum. If a drum holds 10 pounds or more of PCBs, which is the reportable quantity, the entry should read "RQ Hazardous substance, liquid, n.o.s. ORM-E NA 9180 (polychlorinated biphenyls)." If a drum holds less than 10 pounds, the HMR do not regulate the PCBs.
Written by AI (Claude) on Oct 22, 2026. Robots make mistakes and leave things out, so the letter below is what counts. Not legal advice.
This is in response to your letter which requested clarification concerning the proper shipping description to be used on a manifest when shipping capacitors which contain Polychlorinated biphenyls (PCBs).
As explained in your letter, you are putting between ten to twenty capacitor in a plastic bag and then placing fifteen to twenty of these capacitor filled bags in a fifty-five gallon drum, When following this procedure, the proper shipping description is based on the quantity of PCPs in each drum. Since the reportable quantity (RQ) for PCBs is ten pounds, each drum would have to contain ten or more pounds of the PCBs or the PCB in the drum to be considered to be a hazardous substance. Therefore, if the quantity of the PCBs is a drum equals or exceeds ten pounds; the proper shipping description shown on the manifest should be "RQ Hazardous substance, liquid, n.o.s. ORM-E NA 9180 (polychlorinated biphenyls). If the drum contains less then ten pounds of PCBs, the PCBs would not be regulated under the HMR.
Please note that many large capacitors are sufficiently durable in their design and construction so as to qualify as strong, tight containers for purposes of transportation. Provided there is no leakage, PCBs may be transported in these capacitors without additional packaging. When PCBs are transported in this fashion and the capacitor is used as the primary packaging, the proper shipping description is based on the quantity of PCBs in each capacitor, since the capacitor is being used as the package.
I hope this information is helpful in furthering your understanding of the HMR.
A letter of interpretation applies the regulations to the facts the requester described. It isn’t a regulation and isn’t legal advice. The agency’s copy.