Daniels Training Services

Q&A: Segregation of Limited Quantities

Q&A: Segregation of Limited Quantities

A question from a customer of my ONSITE TRAINING on October 15th, 2015:

Hey Daniel,

I just had a quick question regarding limited quantities.  If I have 2 different hazmat items that normally could not be shipped together per the shipping regs but one qualifies under the limited quantities provision then are they able to be shipped together?  The way I interpret the regulations is that if an item is being shipped as a limited quantity it no longer has to be segregated due to the amount since we are also not having to label it as the hazardous material.

Thank you for your input.

(10.15.15)  I was certain he was right about the segregation requirements for a Limited Quantity but I wanted a little more information:

What mode of transportation?  What is the HazMat?

I believe you are right, but I’d like a little more information to be certain.
Dan
And the next day (10.16.15) I got it:

Hey Dan,

So the items are being shipped via ocean.  The 2 hazmat items that I am wanting to put on the same pallet are Nitric Acid(UN2031) and a limited quantity of Silver Nitrate (UN1493).  They will be in their own boxes but on the same pallet.

The International Maritime Organization

The International Maritime Organization regulates the international transportation of dangerous goods by vessel.

Thanks,

With that information I replied with “The Big Answer” on October 17th:

Sorry for the delay, I hope I’m not too late, but my answer confirms yours:

  • Nitric Acid UN2031 may not be shipped as a limited quantity or any other exception under the HMR.
  • Silver Nitrate UN1493 may be shipped as a limited quantity according to 49 CFR 173.152.
  • Interestingly, there is no mention in 49 CFR 173.152 of a limited quantity not being subject to the HazMat segregation requirements.
  • However, 49 CFR 176.80(b) contains an exception for limited quantities from the segregation requirements of the HMR.
  • Nitric Acid UN2031 may or may not be shipped as a limited quantity per the IMDG Code depending on its concentration.
  • Silver Nitrate UN1493 may be shipped as a limited quantity per the IMDG Code.
  • Per 3.4.4.2 of the IMDG Code, the segregation provisions of chapter 7.2 do not apply to packagings of limited quantities.
Therefore, I believe you are correct that the Silver Nitrate UN1493 as a limited quantity is not subject to the segregation requirements of the HMR or the IMDG Code.  However, Nitric Acid UN2031 may not be shipped as a limited quantity within the U.S. (though it may outside of the U.S in some situations) and will be subject to the segregation requirements of the HMR and the IMDG Code.
Non-bulk packaging of HazMat - Limited Quantity

The Limited Quantity marking

I hope this helps.  Please don’t hesitate to contact me with any other questions.

His final reply:
Thanks.  I’m only shipping the Silver Nitrate as the limited quantity with the acid which will be classified as hazardous.
Conclusion/Summary:
Notice from my answer on the 17th that I first determined compliance with the domestic regulations of PHMSA and then those of the International Maritime Organization in the IMDG Code.  The transportation to, from, or through the U.S. is subject to the Hazardous Material Regulations of PHMSA.  If it will also be shipped internationally – in this case on a vessel – then it will be subject to international regulations as well.  Here, the regulations of both PHMSA and the IMO were similar but that may not always be the case.

Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail

International and Domestic

Daniels Training Services

815.821.1550

Info@DanielsTraining.com

http://www.danielstraining.com/

It’s not uncommon that person who have received my Onsite Training follow-up with questions once they begin to apply the information from the training on their job.

Contact me to schedule Onsite Training required by the International Maritime Organization (IMO) every three years, the International Air Transport Association (IATA) every two years, or the Pipeline and Hazardous Materials Safety Administration (PHMSA) every three years.