A question from a customer and reader of my blogs (06.22.20):
Deal Mr. Daniel,
How are you? There was long time no contact, I believe you are doing well.
Recently i am reading your article: “Determining Authorized Packaging for the Transportation of a Hazardous Material”
If a item to be shipped within US domestically by FX Ground, which is UN2925, class 4.1 (8), packing group II, and it can fully satisfy all the requirements of Small Quantity in §173.4, 49 CFR, but it is shown “None” in the field of column 8A, §172.101 Hazardous Materials Table, 49CFR.
Can this item be offered as small quantity packaging by FX Ground? Based on §172.101(i)(1) Column 8A , “None” in Column 8A means no packaging exceptions are authorized, except as may be provided by special provisions in Column 7. The referenced exceptions are in addition to those specified in subpart A of part 173 (which includes Small Quantity in §173.4) and elsewhere in this subchapter.
Best Regards,
My reply at the end of the week (06.26.20):
Thank you for contacting me. I apologize for my delay. Please see below.
- According to 49 CFR 172.101(h)(1), “None” in column 8A means no packaging exceptions are authorized unless provided by special provisions in column 7.
- “None” is present in column 8A of the Hazardous Materials Table for this HazMat (UN2925, Flammable solids, corrosive, organic, n.o.s. 4.1 (8), PG II).
- There are no special provision codes in column 7 of the Hazardous Materials Table that change the conditions of column 8A.
- 49 CFR 173.4 identifies hazardous materials of division 4.1 Flammable Solid as authorized for use of the the small quantity exception.
- However, nothing I can see changes the conditions imposed by the “None” in column 8A. No. I don’t think this HazMat is eligible for transport under the small quantity exception.
- Read: What is the small quantity exception?
I hope this helps. Please contact me with any other questions.
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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, Inc. 815.821.1550 |
Conclusion:
I prefer my answers to be good news for those that contact me and inform them they may transport a HazMat in the manner they wish. That was not the case here. However, it’s better they comply with the regulations than use a packaging exception for which they are not eligible. Make certain your hazardous materials classification is correct before you offer a hazardous material for transportation. Contact me for the USDOT HazMat Employee training that will teach how to get it done.