Question – September 27, 2020

Subject: Mixed hazmat in same packaging

What are the rules for shipping compatible hazardous materials having different hazard classes packed within the same packaging?
What are the quantity limits per package?

I do not find a regulatory reference in 49 CFR for shipping mixed hazmat in the same package. Does such a rule exist?

Thanks!

My reply (10.06.20):

Thank you for contacting me. I apologize for my delay. Please see below.

This reply is based on the Hazardous Materials Regulations (HMR) of the Pipeline and Hazardous Materials Safety Administration within the U.S. Department of Transportation (USDOT/PHMSA).

• The HMR allows for mixed contents of hazardous materials (HazMat) in a packaging.
• 49 CFR 173.24(e)(4) indicates the requirements for compatibility of mixed contents of hazardous materials (HazMat) in a packaging. In summary, it forbids HazMat to be packed or mixed together in the same outer packaging (HazMat or non-HazMat) if the materials are capable of reacting dangerously.
• §173.24a(c) specifies the requirements for the inner and outer packagings when a non-bulk packaging contains mixed contents of HazMat.
• Per package quantity limits only apply if transport is by air. The per package quantity limits by air are indicated in column 9A & 9B of the Hazardous Materials Table. Usually transport by air is done subject to the Dangerous Goods Regulations of the International Air Transport Association (IATA). If so, the IATA Dangerous Goods Regulations differ from the USDOT/PHMSA HMR.

Read: Calculating the “Q” Value for Different Dangerous Goods in a Single Outer Packaging (All Packed in One) for Transport by Air

• §172.404(a) requires a package containing compatible hazardous materials having different hazard classes to display the HazMat label for each HazMat in the package.
• A letter of interpretation LOI 09-0307 mandates the following:
  • The package marks for each HazMat in the package must be displayed.
  • Each HazMat in the package must be described separately on the shipping paper.
• §173.12(b) provides an exception whereby a generic description from the Hazardous Materials Table may be used in place of specific chemical names, when two or more chemically compatible waste materials in the same hazard class are packaged in the same outside packaging. This exception however only applies to lab packs of hazardous waste.

I hope this helps. Please contact me with any other questions.