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Quick Guide: Shipping Hazmat With No Packing Group

Posted on September 20, 2016 by James Griffin

On January 8, 2015 (80 FR 1076), in order to harmonize its rules with international standards, the US DOT Pipeline and Hazardous Materials Safety Administration (PHMSA) amended the 49 CFR Hazardous Material Regulations to remove packing group assignments for several articles.

US and international safety authorities decided to remove packing group assignments from articles for several reasons. Before this rule change, some articles were assigned packing groups (such as wet batteries) and others were not (such as aerosols). When articles were assigned packing groups, the packing groups assigned did not relate to the degree of hazard posed by the material, as packing groups are meant to do. By removing all packing group assignments from certain articles, the regulations become more consistent.

List of Articles No Longer Assigned Packing Groups as of January 2015

UN2017   Ammunition, tear-producing, non-explosive, without burster or expelling charge, non-fuzed
UN2016   Ammunition, toxic, non-explosive, without burster or expelling charge, non-fuzed
UN3506   Mercury contained in manufactured articles
UN3356   Oxygen generator, chemical (including when contained in associated equipment, e.g.,   passenger service units (PSUs), portable breathing equipment (PBE), etc)
UN3268   Safety devices, electrically initiated
UN1700   Tear gas candles
UN3292   Batteries, containing sodium
UN2794   Batteries, wet, filled with acid, electric storage
UN2795   Batteries, wet, filled with alkali, electric storage
UN2800   Batteries, wet, non-spillable, electric storage
UN3480   Lithium ion batteries including lithium ion polymer batteries
UN3481   Lithium ion batteries contained in equipment including lithium ion polymer batteries
UN3481   Lithium ion batteries packed with equipment including lithium ion polymer batteries
UN3090   Lithium metal batteries including lithium alloy batteries
UN3091   Lithium metal batteries contained in equipment including lithium alloy batteries
UN3091   Lithium metal batteries packed with equipment including lithium alloy batteries
 

What's a Packing Group?

Per 49 CFR 171.8, and 172.101(f), "Packing group means a grouping according to the degree of danger presented by hazardous materials. Packing Group I indicates great danger; Packing Group II, medium danger; Packing Group III, minor danger. See §172.101(f) of this subchapter."

The purpose of packing groups is twofold. First, Packing Groups I, II, and III indicate the degree of danger presented by the material as great, medium, or minor, respectively.

Second, the packing groups of hazardous materials line up with the packaging performance levels of certified UN or DOT specification packagings. Only an X-rated packaging is strong enough to hold a greatly dangerous PG I material, though you can put PG II or III in an X-rated unit. Likewise, the medium danger of PG II materials must be in Y-rated packagings at least. Z-rated packagings can only hold PG III materials, which pose minor hazards.
 

What's an Article?

Unfortunately for shippers, the hazmat regulations do not define the term "article." In regulatory and industry circles, the definition used most commonly comes from US-OSHA and means "a manufactured item other than a fluid or particle: (i) which is formed to a specific shape or design during manufacture; (ii) which has end use function(s) dependent in whole or in part upon its shape or design during end use; …." [29 CFR 1910.1200(c)] And while an article may contain hazardous matter, the purpose of the article is more than a container.

For example, a sealed glass ampule holding mercury is a container, not an article. It would be shipped as "UN 2809, MERCURY, 8(6.1)" and assigned to Packing Group II. But a sealed glass ampule holding mercury—when the ampule is in the form of a long cylinder with lines marked on the side for measuring temperature—is a thermometer, a mercury article, and would be shipped as "UN 3506, MERCURY CONTAINED IN MANUFACTURED ARTICLES, 8(6.1)" with no packing group assignment.
 

What Else Doesn't Get a Packing Group?

Hazmat not having a packing group is not a new idea. Materials assigned to Class 2 (gases), Class 7 (radioactive material), and Division 6.2 (infectious materials) never had packing group assignments.

What Does It Mean to Not have a Packing Group?

Without a packing group, you don't automatically know what level of packaging to use for an article like you do for common industrial hazardous chemicals. However, the packing instructions and/or special provisions for articles and other materials without packing groups will always specify the type and strength of packaging to ship the articles.

Not having a packing group doesn't mean much by itself. It means that the packing group section on the shipping papers will be left blank, because there's nothing to put there. [49 CFR 172.202(a)(4)] Also, while marking the PG on the package has never been a requirement, if you do mark your packages with their contents' packing group, you risk noncompliance if packing group assignments no longer apply to your particular article or material.
 

Last Multimodal Hazmat Shipper Workshops of 2016!

The final Complete Multimodal Hazmat Shipper Workshops (49 CFR, IATA, IMDG) of 2016 are starting soon. Get up to speed with the latest rules for hazmat ground, air, and vessel shippers—including new rules for air shipments in the 58th edition IATA Dangerous Goods Regulations—when the workshops come to Kansas City on October 25-28, Detroit on October 31-November 3, Cincinnati on October 31- November 3, Pittsburgh on December 5-8, and Chicago on December 12-15.

Sign up now to keep your hazmat shipments in compliance, in 2017 and beyond!
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Some of the limited quantity reliefs are identical across the intermodal transport rules, but others are reserved for specific modes of transport. Shippers can and should capitalize on these limited quantity reliefs when possible, but must recognize that some hazmat requirements still apply to shipping limited quantities.

Shipping Hazmat Limited Quantities