Q. How much longer can I ship something as a Consumer Commodity, ORM-D?
A. On January 19, 2011, the Department of Transportation (DOT) promulgated a new regulation that phases out the ORM-D classification [76 FR 3308]. In the past, this classification has applied to packages of “consumer commodities.” These are defined as materials that are “packaged and distributed in a form intended or suitable for sale through retail sales agencies…for consumption by individuals for purposes of personal care or household use” [49 CFR 171.8]. In essence, these are typical hazardous materials that are packaged in a form you could find on a store shelf.
ORM-D packages have been given much relief from the regulations, including, but not limited to:
- Not needing to use UN performance tested packaging,
- Not requiring hazard class labels on packages,
- Not requiring placards for vehicles containing ORM-D packages, and
- Not having to create hazmat shipping papers (unless the material is a hazardous waste, hazardous substance, marine pollutant, or going by air or vessel).
To harmonize with other international hazmat regulations (which do not recognize the ORM-D classification), the DOT has decided to phase out ORM-D and simply place these packages under the label “limited quantity.” The good news is that limited quantities still get the same relief as ORM-D. The only real practical difference for most shippers is that the markings on the outside of the package will be slightly different.
There are actually two phase-out dates for the ORM-D classification. For those that ship materials as ORM-D-AIR (which is more uncommon), the last acceptable date is December 31, 2012. Then, one year later, on December 31, 2013, the common ORM-D classification will come to an end.
It is important to note you do not have to wait until these dates to ship something under the new limited quantity reliefs. You can switch over to the new limited quantity rules at any time during this transition period.