Q. What are Excepted Quantity shipments? How do I prepare small packages as excepted quantity shipments by ground and by air?
A. Did you know there is a way to avoid almost all of the hazardous material regulations, to ship hazmat with no special packaging, no hazard labels, and no special shipping papers? There’s only one catch: You can’t pack more than an ounce per bottle.
Ground Shipments of Excepted Quantities
When shipped by highway or rail, most medium- and low-hazard materials are not subject to the hazardous materials regulations when packaged in very small combination packaging. These include most Division 2.2; Class 3; Division 4.1; Division 4.2 and 4.3 (in PG II or III); Division 5.1, 5.2., and 6.1; and Class 7, 8, and 9 materials. They must be in inner packages under an ounce, with the exception of Division 6.1 PGI materials, which may only be 0.04 ounces, and Division 2.2, which is restricted to a 30 mL water capacity container. Additionally, the entire package may not exceed 64 lbs.
While these packages do not need to meet the general packaging requirements outlined in 49 CFR 173, Subpart B, there are still some packaging standards that must be met. The inner receptacles have minimum thickness requirements, they must have cushioning that could absorb the entire liquid contents, and the package must be able to pass some simple dropping and stacking test. Finally, while you do not have to follow the marking requirements for hazardous materials, you must certify that the package complies with the excepted quantity limitations by writing “This package conforms to 49 CFR 173.4 for domestic highway or rail transport only” on the exterior of the package.
Air Shipments of Excepted Quantities
Air shipments are much more difficult. Fewer materials are authorized as excepted quantities, and the quantities are much more limited. In the IATA List of Dangerous Goods, Column F indicates if a material qualifies and is a reference for a table in Section 2.6 of the IATA regulations that determines inner and total package limitations. There are two ways that Column F can indicate a material will not qualify as an except quantity; if a material is forbidden by air, the column will be blank, and if it simply cannot be shipped under this relief, there will be an E0. Other materials can qualify if an E1, E2, E3, E4, or E5 is indicated in Column F, and these codes indicate the quantity limits for inner and outer packagings ranging from at most 1 ounce per inner packaging in a package containing no more than 2.2 lbs. of material, down to 0.04 ounce inner packagings in packages containing 10 oz. or less altogether.
While the relief is very similar, there are a few significant differences. For example, you do not get any relief from training and reporting requirements. You must also place the excepted quantity package mark (IATA 18.104.22.168) and fill in the hazard class and shipper’s or consignee’s name if the name is not elsewhere on the package already. And if a shipping document is used, it must include the statement, “Dangerous Goods in Excepted Quantities”
Get more information on packaging requirements, excepted packages, and excepted quantities at any of Lion Technology’s Ground, Air, or Vessel Hazmat Shipper Courses.
Will you benefit from using these excepted quantities rules? What other exceptions do you use to your advantage?