Over the next few years, the Department of Transportation is phasing out the old ORM-D classification for consumer commodities and replacing it with an expanded universe of limited quantity authorizations. In most cases, the only difference for the end-user will be replacing the rectangular ORM-D, CONSUMER COMMODITY marking with the new diamond Limited Quantity marking.
Many consumer commodity hazmats are transported in small packages, with dimensions only 4 or 6 inches wide. Because the DOT’s new limited quantity marking is larger than the older ORM-D, CONSUMER COMMODITY marking, shippers may have difficulty fitting all necessary marks and labels on smaller consumer commodity packages.
Whether the marks/labels are pre-printed or affixed at the time of shipping, it can be expensive to reorganize labels or affix them to the same side of a package to make them fit.
According to the Hazardous Materials Regulations, each limited quantity marking must be durable, legible, of a size relative to the package that is readily visible, and at least 100 mm (4 inches) on each side, unless the package size requires a reduced-size marking. [49 CFR 172.315; emphasis added]
This phrase has traditionally been interpreted by shippers to mean that reduced-size markings are authorized only when the full-sized marking will not fit on the package. In the letter of interpretation from October 1, 2012 (12-0177), however, PHSMA authorized reduced-size markings “…to the extent necessary to accommodate pre-printing of [the] additional information needed with the limited quantity marking.”
This means that you can use a reduced-size (down to 50 mm) limited quantity marking on a package, even when the full-sized (100 mm) marking will fit. This is similar to provisions that already exist in IATA 184.108.40.206. By using a reduced-size label, you can free up room for other markings to ensure you communicate all the critical information on your package in a way that’s easy for shipping personnel, carriers, and first responders to recognize and use.
Learn the latest rules and exclusions available for shipping limited quantities of hazardous materials by ground, air, and ocean! The Shipping Limited Quantities and Consumer Commodities online course covers the 49 CFR, IATA, and IMDG rules your personnel must know to prepare limited quantity shipments for transport by any mode.