Shipping Limited Quantity Domestic vs. International
When shipped by ground, air, or ocean, a number of common household items are regulated as hazmat by the US Department of Transportation. Because they are common and largely low-risk materials, many household cleaners, medicines, and cosmetics are afforded certain reliefs when packaged as a limited quantity. When packaged in certain ways, these items are also sometimes referred to as consumer commodities.
While these two terms, "limited quantity" and "consumer commodity," are sometimes used interchangeably, they each refer to a specific type of hazmat package with unique requirements. Understanding the difference between "limited quantity" and "consumer commodity" is critical to ensure your packages are correctly marked, labeled, and documented. The regulations that apply will vary based on the type of material, the packaging used, and the mode of transportation (ground or air).
Limited Quantity or Consumer Commodity?
The DOT defines a limited quantity as the maximum amount of a hazardous material for which there is a specific labeling or packaging exception. [49 CFR 171.8] If a material is listed in the HMR Table at 49 CFR 172.101, with an entry in column 8A-Exceptions, then the DOT authorizes that material for exception from regulations, almost always as a limited quantity. [49 CFR 172.101(i)]
Limited quantity shipments may qualify for further exceptions from the HMR if the package(s) meet the definition of a consumer commodity. The DOT defines a consumer commodity as a material that is "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 the past, shippers had the option to reclassify these packages as ORM-D and ship them under the name CONSUMER COMMODITY. ORM stands for Other Regulated Materials. Today, the reclassification and renaming of consumer commodity packages is no longer necessary, though it is still acceptable for domestic ground shipments until 2020.
In order to simplify the requirements for shipping small amounts of hazmat, on January 19, 2011, the DOT expanded the exceptions for limited quantity to include the exceptions previously only available for consumer commodities (most significantly, an exception from the hazmat shipping paper requirement). In other words, the Consumer Commodity distinction is no longer needed for ground shipments because ALL limited quantity ground shipments are now exempted from the hazmat shipping paper requirement under the HMR. [76 FR 3308]
Reliefs for Domestic Ground Shipments (49 CFR)
Under DOT rules, limited quantity shipments (including consumer commodities) are afforded reliefs from the following hazmat shipping requirements:
- UN specification performance-oriented packaging,
- Hazmat markings (Proper Shipping Name and ID number),
- Hazard labels,
- Hazard placards, and
- Shipping papers and emergency response information.
These reliefs apply as long as the limited quantity package meets the following conditions:
- The material is not a hazardous waste, hazardous substance, or marine pollutant.
- The material is packed in a combination packaging with a strong outer package.
- The material is marked with the limited quantity marking. [49 CFR 173.315]
- The ORM-D marking may be used through December 31, 2020 for domestic ground shipments of materials reclassified as consumer commodities.
- If the package contains liquids, orientation arrows must be marked on two opposing sides of the package.
- The package can be no heavier than 30 kg (66 lbs.) gross weight.
- For inner packagings, the size limit varies based on hazard class, division, and packing group of the material. These limits range from 100 mL to 5.0 L for liquids and 0.5 kg to 5.0 kg for solids, depending on the severity of the hazard. [49 CFR 173.150-173.156 and 173.306]
Additional Requirements for International Air Shipments (IATA)
When a limited quantity of hazmat is shipped by air under the International Air Transport Association (IATA)Dangerous Goods Regulations or under 49 CFR domestically, many of the reliefs for domestic shipments do not apply. Air shipments of limited quantities are subject to the following requirements:
- The shipment must be authorized at the PG II, or Y, level.
- Packages must meet the aviation pressure tests. [49 CFR 173.27]
- Packages must be marked with the "Y" version of the limited quantity marking to indicate eligibility for air transport.
- The package must be accompanied by standard hazmat shipping papers, or a Shipper's Declaration of Dangerous Goods, that describes the hazmat with a standard basic description (ID number, Proper Shipping Name, hazard class, and packing group). [49 CFR 173.150-173.156 and 173.306; IATA DGR 2.7]
Limited quantity air shipments may still qualify for additional relief as consumer commodities under the air shipping rules, provided very specific criteria regarding the type and quantity of hazmat are met. If this is the case, shippers may reclassify and rename their limited quantity air shipments as "ID8000, CONSUMER COMMODITY, 9, II." [49 CFR 173.167, IATA DGR PI Y963]
Note: Shippers may no longer use the ORM-D classification for domestic or international air shipments. The ORM-D AIR classification has been officially phased out. The ORM-D classification may be applied to hazmat ground shipments only until 2020.
By understanding the hazmat shipping requirements for even the smallest packages, shippers can take advantage of the reliefs afforded to limited quantities and consumer commodities. Because the regulations vary depending on the material and the mode of transport, it is critical to check the regulations before signing off on a package to make sure the shipment will arrive safely and on time.
Ensure all of your hazmat shipments are prepared to ship by all modes with complete multimodal training. At Lion Technology's Multimodal Hazmat Shipper Certification Workshop, you'll learn the DOT, IATA, and IMDG hazmat shipping regulations. Comprehensive and effective training is essential to avoiding costly fines, penalties, and shipping delays.
Tags: DOT, hazmat shipping, IATA, limited quantities
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