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Small Quantities, Big Differences

Posted on 5/8/2020 by Roseanne Bottone

The reliefs and requirements for shipping limited quantities of hazardous materials (i.e., dangerous goods) can vary greatly from one mode of transportation to another. Here we break down what's required if you ship limited quantities by ground (49 CFR), air (IATA DGR), or vessel (IMDG Code).

The Shipping Limited Quantities and Consumer Commodities online course provides reliable, up-to-date training to help satisfy DOT, IATA, and IMDG training mandates for hazmat employees who prepare or offer limited quantity shipments for ground, air, or vessel transport.

Where to Find Quantity Limits

All modal regulations limit the quantity of hazardous materials/dangerous goods allowed in inner packagings.

The quantity limit for each mode of transport is indicated:

49 CFR hazmat ground shipping In the 49 CFR Part 173 packaging instruction referenced in Column 8A of the 172.101 shipping table
Dangerous goods IATA air shipper In the packing instruction in Section 5 referenced in Column G of the IATA DGR 4.2 DG List
dangerous goods IMDG shipper In column 7A of the IMDG Code 3.2 DG List 

Since air transportation is more stringent, IATA limits the total quantity of DG per package.

In addition, each set of modal regulations limits the total weight of hazmat/DG per package for that mode of transport. For most limited quantity packages, those limits are:

49 CFR hazmat ground shipping 30 kg (66 lbs.) mass 
Dangerous goods IATA air shipper 30 kg mass* 
dangerous goods IMDG shipper 30 kg mass

* For air shipments, total quantity limit found in Column H of the IATA DGR 4.2 DG List.

Packaging Hazmat Limited Quantities 

Now that we know how much we can ship, let's start packing it up.

All modes of transport require the use of combination packaging for limited quantities of hazmat/dangerous goods. But because we're talking about very small quantities, shippers are  not required to use packagings that have been tested and marked with UN specification markings.*

Shippers must use a "strong outer packaging" for limited quantity shipments.

Note: The IATA DGR states that the package "must be capable" of passing certain packaging tests (2.7.6.1 and 2.7.6.2 and 6.6.1 and 6.6.2)

Marking and Labeling Hazmat Limited Quantities 

For packages other than those containing hazardous substances or hazardous wastes, the DOT and IMDG require only the “surface” limited quantity marking (i.e., a blank white area), and orientation arrows if the package contains liquid.

IATA requires the use of the air limited quantity marking (i.e., a “Y” indicated in the white area) and all marks and labels as if it were a fully-regulated package.

49 CFR hazmat ground shipping
For ground shipments:
  • Limited quantity mark
  • Orientation arrows (for liquids
Dangerous goods IATA air shipper
For air shipments:
  • Air limited quantity mark ("Y") 
  • Orientation arrows (for liquids)
  • Proper shipping name
  • UN ID # 
  • Shipper's address
  • Consignee's address
  • Hazard label(s)
  • Quantity (if packages differ)
dangerous goods IMDG shipper
For vessel shipments:
  • Limited quantity mark
  • Orientation arrows (for liquids)

 

Are Hazmat Shipping Papers Required for Limited Quantities? 

The DOT does not require shipping papers for most limited quantities unless they are a hazardous waste, hazardous substance or marine pollutant. IATA and IMDG always require shipping papers for limited quantities.

49 CFR hazmat ground shipping Not required Shipping papers are not required for limited quantities by ground. 
Dangerous goods IATA air shipper Required  The "Y" packaging instruction indicates that the package is a limited quantity. 
dangerous goods IMDG shipper Required  The words "limited quantity" or "Ltd. Qty." must be added to the end of the basic description.

Hazmat Placards

When's the last time you saw a hazmat placard on the side of an airplane? Hopefully never.

The hazardous materials placarding requirements for limited quantities vary depending on the mode of transport.

49 CFR hazmat ground shipping No placards required
Dangerous goods IATA air shipper Not applicable 
dangerous goods IMDG shipper No placards required*

*For vessel shipments, the large limited quantity mark is required if the freight container is transporting only limited quantities.

Hazmat Training (Initial and Recurrent) 

Personnel who prepare and offer limited quantity hazmat packages and/or shipping papers  must be trained.

In the US, all hazmat employees must complete general awareness, function-specific, security awareness training. When applicable, safety training and training on your site’s written cargo security plan is also required (see 49 CFR 172.704).

Hazmat training must be repeated regularly to ensure employees' know their responsibilities and hold knowledge that's up to date with the latest regulations. Employers must provide initial and recurrent hazmat training at the intervals below, as well as whenever regulations change that impact the employee's duties.

The timing for  hazmat training is as follows:

  Initial Hazmat Training Recurrent Hazmat Training
49 CFR hazmat ground shipping

Within 90 days of hire date or becoming a "hazmat employee"
(49 CFR 172.704)

Every 3 years
Dangerous goods IATA air shipper

Upon employment or becoming a "hazmat employee"
(IATA DGR 1.5)

Every 2 years
dangerous goods IMDG shipper

Follow the mandate of your "competent authority" *
(IMDG 1.3.1)

Every 3 years 

* In the US, US DOT PHMSA is the "competent authority." Dangerous goods vessel shippers must comply with the hazmat training requirements at 49 CFR 172.704.

When preparing your limited quantities for shipment, always reference the specific requirements for the mode of transportation you’ve chosen.

Want More on Limited Quantities?

The phase-out of the ORM-D designation for highway limited quantity shipments officially ends on January 1, 2021.  If you ship ORM-D, be confident you know how to package, mark, and label your limited quantity shipments after ORM-D goes away.

The Shipping Limited Quantities and Consumer Commodities online course provides reliable, up-to-date training to help satisfy DOT, IATA, and IMDG training mandates for hazmat employees who prepare or offer limited quantity shipments for ground, air, or vessel transport.

Tags: 49 CFR, hazmat shipping, IATA, limited quantities, ORM-D

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