An email I received December 17, 2015 (I swear I am not making this up!):
Hi Daniel,
I have a question regarding the hazmat shipping exception: Small Quantities for Highway and Rail. I’m trying to ship an order of chemistry sets which have 8 hazardous materials:
(3 grams) Calcium Metal UN1401 4.3
(25mL) Hydrogen Peroxide UN2984 5.1
(20 grams) Magnesium UN1869 4.1
(25 grams) Potassium Persulfate UN1492 5.1
(1 gram) Silver Nitrate UN1493 5.1
(15 grams) Potassium Permanganate UN1490 5.1
(30 grams) Sodium Hydroxide UN1823 8
(20mL) Sulfuric Acid UN2796 8
Each chemical is in either Packing Group II or III. To my best judgement, this falls under the Small Quantities exception. Is that correct? Also, would the class 8 materials need to be shipped separately? When I researched segregation/compatibility, class 8 was the only class that raised an issue. Any help is greatly appreciated.
(12.18.16) I was traveling and figured that a short answer was better than no answer, so I pointed him to the applicable regulation:
I can give you a quick answer right now.
Based on the information you’ve provided, I suggest you refer to 49 CFR 173.161 for packaging instructions for chemical kits and first aid kits.
A few days later, and back in the office, I decided to see if I could be of any more help (12.22.16):
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A little too late for Christmas but he did write me back on January 4, 2016:
Sorry for the delayed response. If I were to ship the sets using the Small Quantities for Highway and Rail method, is the package still considered hazmat? There isn’t a large price difference in shipping the sets as hazmat, I’m just curious if I need to mark them as such or not.
My reply that day:
The packing instructions of 49 CFR 173.161 allows for the transportation of chemical kits per the Small Quantity or Excepted Quantity exceptions. If so, they still remain a hazardous material but are excepted from most of the requirements of the hazardous material regulations, e.g. specification packaging, shipping papers, HazMat labels, HazMat Employee training (perhaps!).
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I hope that limited assistance was enough to keep me on the “Good” list.
Don’t you hesitate to contact me with any questions you may have about the transportation of chemical kits, first aid kits, or any other hazardous material.