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Hazmat Tricks & Treats: Finding Sweet Shipping Reliefs

Posted on 10/29/2021 by Ross Kellogg, CHMM

US DOT's Hazardous Materials Regulations (HMR) contain strict shipping requirements. Shippers who know where to look, however, can find substantial reliefs available for specific situations and industries.  

To explore some shipping reliefs and exceptions with a Halloween twist, today we will ship a new product we invented called the "Young Frankenstein Re-animator Kit." Our goal is to take advantage of as many HMR reliefs as we can to ship our new product in a cost effective and efficient way.

Our Re-Animator Kit contains supplies that kids can use to become the next Dr. Frankenstein: 
  • One small specimen of a mammal or bird containing small quantities of Ethanol (UN 1170), Formaldehyde solution, flammable (UN 1198)
  • One power source, a dry battery, i.e., a gelled alkaline electrolyte battery
  • Two capacitors to help build the needed charge
We’re shipping a flammable liquid, a battery, two capacitors, and a no-longer-living animal. We know that this is probably going to be regulated. That’s a good start! Before we can package or ship our product, we need to classify it and name it.
Recurrent DOT hazmat training november 16

Hazmat Classification & Naming Reliefs

Starting with the embalmed bird or mammal included in our Kit, It’s tempting to “over-classify” it a “Biological substance, Category B, 6.2, UN 3373.” It might also be a “Flammable liquid NOS, UN 1993” due to the individual preservatives.

But we find exactly what we need in the de minimis exceptions at 49 CFR 173.4(b), which reads:
“Non-infectious specimens, such as specimens of mammals, birds, amphibians, reptiles, fish, insects and other invertebrates containing small quantities of Ethanol (UN1170), Formaldehyde solution, flammable (UN1198), Alcohols, n.o.s. (UN1987) and Isopropanol (UN1219) are not subject to the requirements of this subchapter, provided the following packaging, marking and documentation provisions, as applicable, are met”

“Not subject to the requirements of this subchapter” means not subject to regulation as hazmat. This provision says that as long as you follow a few basic requirements for packaging, package markings, training employees, etc., the remaining hazmat regulations do not apply.
This is a good time to practice your mad scientist laugh. 
Note: De minimis quantities of our hazardous mateirial are restricted in carry-on and checked baggage during air travel. That's something to consider if our sales team plans to bring samples to the annual Halloween Conference in Orlando.     
Frankenstein's monster

Batteries Included…

We include a dry battery with our Re-Animator Kit. Luckily for us, the 49 CFR hazmat regulations hold special reliefs for batteries and capacitors like the ones in our kit—if you know where to look.
In this case, you can find the relief in Column 7 of the 172.101 Hazmat Table—Special Provisions.

The Hazmat Table names the dry battery in our kit as “Batteries, dry, sealed, n.o.s.” Column 7 for this material references Special Provision 130. SP 130 defines this type of battery and states that it is not subject to requirements of this subchapter, provided you follow certain protocols.
We have to package the batter to prevent sparks and short circuits in transit. In air transportation, our battery will be subject to additional rules for package markings, shipping papers, and incident reporting apply to air transportation.

Hazmat Reliefs for Capacitors

Lastly, we have our capacitors, which will help us get sufficient charge for our unnatural experiments! Due to the small size of our reanimation test subjects, our capacitors have a low voltage capacity.

Returning to the 49 CFR 172.101 Hazmat Table, we find an entry specific to capacitors: “Capacitor, electric double layer (with an energy storage capacity greater than 0.3Wh).”

Since our capacitors fall below this Watt-hour capacity, it seems to indicate that our capacitors are not going to be regulated as hazmat. In fact, the Special Provision in Column 7 (SP 361) defines "capacity." This confirms that our capacitors are not regulated in this subchapter and are not hazardous materials.
DOT hazmat ground shipper training

Now we’re ready to package and ship the Young Frankenstein Re-animator Kit—just in time for Halloween! By taking the time to find the reliefs that apply to our materials, we were able to use the "tricks" of the hazmat shipping trade to find reliefs that reduce our regulatory burden and simplify the compliance process. 

That's a treat everyone can enjoy. Happy Halloween!

Have No Fear: Simplify Hazmat Shipping Compliance

Join Lion for expert-led webinar training to simplify your approach to hazardous materials compliance. Or train at your own pace with online courses designed by credentialed subject matter experts to help satisfy 49 CFR, IATA DGR, and IMDG Code training mandates. 

Hazmat Ground Shipper Certification (DOT)  
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Hazmat Vessel Shipper Certification

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Tags: 49CFR, DOT, hazmat shipping

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