ORM-D Phase-out Ends Dec. 31, 2020
ORM-D is already phased out of air and vessel transportation, and its days in ground transport have been numbered since 2011 when DOT finalized rulemaking HM-215K to harmonize 49 CFR with international standards for limited quantities.
Before & After Jan. 1, 2021
The graphic at right shows you how to prepare an "ORM-D" package for highway transportation after the phase-out ends on December 31, 2020. Click to see a bigger version.
To explore the rules for shipping limited quantities by ground, air, and vessel, check out this recent blog:
Small Quantities, Big Differences
What is ORM-D?The ORM-D classification is used for materials that meet the DOT definition of a consumer commodity.
49 CFR 171.8 defines a consumer commodity as a “material that is packaged and distributed in a form intended or suitable for sale through retail sales agencies or instrumentalities for consumption by individuals for purposes of personal care or household use.”
Shippers who use the ORM-D classification for ground transport benefit from a multitude of reliefs. Hazardous materials classed as ORM-D are typically excepted from the following shipping requirements:
- UN specific packaging
- Hazmat labels
- Shipping papers (unless the material is a hazardous waste, hazardous substance, or marine pollutant)
- Hazmat placards
ORM stands for Other Regulated Materials and was used in a series of hazmat classifications under US DOT regulations: ORM-A, ORM-B, ORM-C, ORM-D, and ORM-E. While the other ORM classifications were phased out long ago, ORM-D remained in place.
Here’s some good news: For the most part, the same materials, in the same quantities, in the same packaging, will continue to qualify for relief under US DOT’s limited quantity regulations after ORM-D is phased out. When PHMSA began the ORM-D phase out in 2011, they also expanded the limited quantity exceptions to include the same reliefs provided for ORM-D.
What Happens to ORM-D Shipments on January 1, 2021?
Limited quantity shipments are typically excepted from UN specification packaging, hazmat labels, shipping papers, and hazmat placards.
What will change is the label you affix to your packages. Ground shipments of limited quantities must carry the blank limited quantity mark pictured below. Limited quantity air shipments are already required to display the “Y” limited quantity marking shown below.
ORM-D Example: Nail Polish RemoverYou ship nail polish remover and you have always shipped it properly under the ORM-D classification. When the clock strikes midnight for New Years 2021, you can no longer utilize that ORM-D classification.
With or without ORM-D, you can still get your package where it needs to go. You just have to use the right marking. After December 31, 2020, you will no longer mark your package with “Consumer Commodity,” the ORM-D marking, and the shipper’s or consignee’s name and address.
Instead, you will use the “new” white square-on-point limited quantity marking for ground shipments shown above. If you ship liquids, orientation arrows are also required [49 CFR 172.312(a)(2)].
Hazmat Training for Limited Quantity ShippersEven if you ship limited quantities of hazardous materials—you still ship hazardous materials. Hazmat training is required for all employees who can affect the safety of hazmat shipments in transport. 49 CFR 172.704 requires that all employees receive general awareness, security awareness, and function-specific hazmat training.
For employees who prepare limited quantities for ground transport, training should cover the packaging, marking, and labeling rules they must follow when the ORM-D phaseout is complete.
The Shipping Limited Quantities and Consumer Commodities online course will prepare personnel to navigate and use the limited quantity regulations to ensure your shipments continue moving safely, in compliance, and on time—in 2021 and beyond.
The course covers a step by step process to identify, package, mark, label, handle, and document limited quantity shipments for transport by ground, air, and vessel.
Prepare for 2021To get through the ORM-D phaseout unphased, update your employees' hazmat training now, and continue to provide required re-training once every three years.
Lastly, limit your purchase of new ORM-D marks and use up your existing stock before the December 31, 2020 deadline. After that date, ORM-D will officially be relegated to the hazmat history books.
Tags: hazmat shipping, limited quantities, new rules, ORM-D
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