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…
Q&A: How can I ship cosmetics as a Class 3 Flammable Liquid?
A question from someone who found – and liked – my blog on June 26, 2015: Dear Daniel, I hope this message finds you well. I found your website online and I find it very helpful and educational. I haven’t…
49 CFR 173.6 – The Materials of Trade Exception
Shipment of Empty HazMat Packagings and the Need for HazMat Labels, Placards, Markings, & etc.
49 CFR 173.29 contains the PHMSA/USDOT regulations for the transportation of empty packagings that last contained hazardous materials. As a shipper of hazardous materials you must be aware of §173.29(a) which states that an empty packaging with the residue of…
“Emptying” a Hazardous Material Packaging
In the Hazardous Material Regulations (HMR) at 49 CFR 173.29(a) you learn that as far as the PHMSA/USDOT is concerned, the transportation in commerce of an “empty” packaging that still contains the residue of a hazardous material is subject to…
What is the Small Quantity Exception to the HMR?
The transportation of a hazardous material (HazMat) is subject to the Hazardous Material Regulations (HMR) of the PHMSA/USDOT. This includes but is not limited to the following: Classification of the HazMat. Selection and use of specification packaging. Application of the…
Authorization for use of ORM-D Classification (Consumer Commodity) Extended to end of 2020!
Announced January 7, 2013 in the Federal Register and effective January 1, 2013, the PHMSA of the US Department of Transportation granted the request of the American Coatings Association (ACA) to extend the authorization for use of the ORM-D classification and the…
What is the Consumer Commodity Exception to the Hazardous Material Regulations?
A substance or material that the US DOT has determined is capable of posing an unreasonable risk to health, safety, and property will be regulated as a Hazardous Material when offered for transportation or transported in commerce. Some Hazardous Materials…
What is an Other Regulated Material (ORM-D)?
49 CFR 171.8 reads, “ORM means other regulated material. See §173.144 of this subchapter.” That’s not much to go on but it’s a start. §173.144 defines an ORM-D as: Until December 31, 2013 and for the purposes of this subchapter, “ORM-D material”…
Former and Present Other Regulated Materials (ORM)
Currently, and only until December 31, 2013 when it will cease to exist (unless an extension requested by US DOT to December 31, 2015 is granted), there is only one category of Other Regulated Material. In the distant past (known…