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?

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 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.

The Limited Quantity marking

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

His final reply:

Conclusion/Summary: