New Hazmat Special Permit Allows Smaller Limited Quantity Marking

Posted on 9/8/2020 by Roger Marks

US DOT PHMSA issued a new hazmat special permit (DOT-SP 21015) that allows for the use of a reduced size limited quantity marking as small as 25 mm on each side when shipping limited quantities domestically by highway, rail, or vessel.

The special permit does not apply to air transport or international transport by any mode. 

Shippers granted use of this special permit must meet certain conditions when using the reduced size limited quantity marking, including:
  • Each package must bear a carrier specific tracking label that can electronically communicate to carriers that the package contains hazardous materials shipped under a limited quantity exception, and that transport by air is not authorized;
  • Shippers using the special permit must provide training materials to carriers who accept the packages;
  • The limited quantity marking must be at least 25 mm on each side and placed in the upper right quadrant of the package tracking label; and
  • The special permit number “DOT-SP 21015” must be marked on the same surface as the tracking or shipping label.
Last, the reduced size limited quantity label is not authorized for use on the outside of an overpack.

PHMSA granted party status to the new special permit to, Inc. and Midway Arms, Inc. These authorizations expire on July 31, 2022.

Read the full text of the special permit.

PHMSA previously authorized the use of a reduced size limited quantity label (as small as 50 mm) for smaller packages, "to the extent necessary to accommodate pre-printing of the additional information needed with the limited quantity marking." See PHMSA Interpretation 12-0177

Hazmat Training for Employees

The text of the special permit states that “hazmat employees” who prepare packages under this special permit must receive training on the requirements and conditions of the special permit. Training specific to the special permit is required in addition to the hazmat training required for all “hazmat employees” at 49 CFR 172.704.

Hazmat training for packagers. 

Join the Special Permit Party  

When PHMSA grants a shipper authorization to use a hazmat special permit, the shipper has gained “party status” to the permit.

If you want to start using a smaller limited quantity mark authorized under this new special permit, this should help: In April 2020, Lion hazmat instructor Flip De Rea covered how to request party status for a hazmat special permit—including the “party rules” you have to follow to use a special permit.

Shipping ORM-D After 2020

The Other Regulated Materials–Domestic (ORM-D) designation for hazardous material "consumer commodities" shipped by ground will no longer be authorized after December 31, 2020. Consumer commodities are defined as hazardous materials "packaged and distributed in a form intended or suitable for retail sale..." (49 CFR 171.8). 

The good news for ORM-D shippers is that, for the most part, the same materials, in the same quantities, in the same packaging will continue to qualify for relief under DOT's limited quantity regulations. 

Read more: What Happens to ORM-D Shipments on January 1, 2021?

To get through the ORM-D phaseout unphased, update your employees' hazmat training now, and continue to provide required re-training once every three years. 

Hazmat Training for Limited Quantity Shippers  

Even 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. If you're concerned about the ORM-D phase out ending this year, this course will prepare you to keep your shipments moving uninterrupted. 

Tags: hazardous materials, hazmat shipping, limited quantities, ORM-D, special permit

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