Q&A: Do I display the HazMat’s identification number on the limited quantity sticker?
Question (11.23.21):
Hi Daniel,
I saw your video on YouTube and had a couple questions I was hoping you could answer for me. Regarding Limited Quantities, does the UN number get written on the Limited Quantities sticker?
Answer (11.23.21):
Thank you for contacting me. Please see below.
No. the ID# for a HazMat is never displayed on the limited quantity mark. Nothing may be displayed on the limited quantity mark.
The ID# is not displayed anywhere on a package of a limited quantity unless it is to be transported by air.
The only required marks and labels on a limited quantity by highway, rail, or vessel is the following:
The limited quantity mark.
Orientation arrows (displayed on two opposite vertical sides) if the HazMat is a liquid.
I hope this helps. Please contact me with any other questions.
Interested in a site specific Webinar that covers this topic, and more?
Exceptions to the HazMat transportation regulations – such as the limited quantity exception – provide an opportunity for shippers of HazMat to save time and money when offering HazMat for transportation. However, care must be taken to ensure compliance with the requirements of the exception. My HazMat Employee training focuses on this and other packaging exceptions if applicable to your operations. Just let me know what you need and I will include it in your training.
Changes to the Limited Quantity Exception for Hazardous Materials in 2021
In a Final Rule issued November 25, 2020 the Pipeline and Hazardous Materials Safety Administration within the U.S. Department of Transportation (USDOT/PHMSA) amended it Hazardous Materials Regulations (HMR) to clarify, update, and provide relief from various regulatory requirements. A review of the entire Final Rule and its impact on the HMR is not the purpose of this article (whew!). The purpose of this article is to identify and explain two changes to the HMR from this Final Rule related to the classification and packaging of certain hazardous materials (HazMat) under the limited quantity exception.
Notice of Proposed Rulemaking (NPRM) issued: August 14, 2019
Final rule published in Federal Register: November 25, 2020
Effective date: December 28, 2020
These changes to the HMR apply solely to HazMat offered for transportation and/or transported anywhere to, from, or through the U.S. However, the changes to the Limited Quantity exception were done at least in part to harmonize the HMR with existing international regulations. Therefore, the relief from regulation offered by this Final Rule already exist in the international regulations of the following:
Of the nineteen changes made by this Final Rule, two of them affect the regulations of the limited quantity exception:
Limited Quantity for Hydrogen Peroxide:
The rule establishes a limited quantity provisions of 1 L per inner container for UN2014, Hydrogen peroxide, aqueous solution. This is for solutions between 20 and 60% hydrogen peroxide. USDOT/PHMSA recognized that international regulations and standards already permitted this substance to be transported as a limited quantity, so it was an anomaly that the HMR didn’t allow such an exception. Therefore, USDOT/PHMSA revised Column (8A) of the HMT for “UN2014, Hydrogen peroxide aqueous solution” to allow limited quantity packaging for this material by referencing the exception in 49 CFR 173.152.
Limited Quantity Harmonization:
A petitioner requested USDOT/PHMSA to extend the eligibility of the limited quantity exception to 45 additional hazardous materials. Just as for UN2014, Hydrogen peroxide aqueous solution (see above), these HazMat were already eligible for the exception under the international standards. USDOT/PHMSA conducted a technical review and determined that a total of 114 entries on the Hazardous Materials Table – including the 45 originally requested – are not in alignment with the UN Model Regulations permitting limited quantity shipment of hazardous materials. During its review USDOT/PHMSA also determined that these hazardous materials currently without limited quantity exceptions are of the same hazard classes as materials for which the HMR already contains an exception allowing limited quantity shipment.
Based on its technical review USDOT/PHMSA came to the following conclusions:
Prior to this revision, the HMR’s limited quantity exception was inconsistent with the international standards.
Expanding the applicability of the limited quantity exception would not adversely affect safety.
Significant changes to the Hazardous Materials Regulations can occur with or without your knowledge. While USDOT/PHMSA HazMat Employee training is required triennially (every three years), it may not hurt to attend training more frequently.
Q&A: Is my product a marine pollutant? A limited quantity? A hazardous material?
A question June 16, 2020:
Good afternoon Daniel. I hope you are doing well.
I have a question for you that I hope you can help me to clear up.
We have this product available in 11 oz tubes (caulking), 1 gallon plastic containers and 5 gallon buckets. See below for SDS Transportation section…
My question is regarding whether or not this item is regulated and needs to be noted on a BOL or requires markings or labels for over the road shipments (DOT).
I noticed the Remarks below stating that labeling is not required when shipping non-bulk loads.
Are we able to ship this without any requirement for noting it on the BOL or any markings or labels needed?
Curious about what is required (if anything) on these:
11 oz tubes
1 gallon tub
5 gallon bucket
Appreciate your help on this Daniel.
Thank you in advance.
My reply the same day:
I can assist you. Please see below.
Sections 12-15 of the SDS are not authorized for use within the U.S. I prefer to see the entire SDS.
Based on the information in section 14 (see bullet point above), this material is a marine pollutant per international and domestic regulations.
Per international and domestic regulations a marine pollutant in a single or combination packaging of 5 L / 5 kg or less is not subject to international or domestic regulation. Yours likely will be above these thresholds and therefore not eligible for the exception. Read: The Marine Pollutant Exception
Within the U.S. transport by highway, rail, or air (unlikely) of a marine pollutant is not subject to any regulation if it is in a non-bulk packaging i.e., ≤454 L (119 gal).
If the material is indeed a marine pollutant (not certain, but we’ll assume it is) it is not subject to any USDOT/PHMSA regulations when transported in commerce within the U.S. by highway or rail in the packaging quantities you indicate.
If ever transported in a packaging with a capacity of more than 119 gallons, it may be subject to regulation as a Class 9 Miscellaneous, Marine Pollutant.
I hope this helps. Please contact me with any other questions.
Marine Pollutant mark
He still had questions, so the next day:
Thank you Daniel.
I have attached the complete SDS copies for both products.
Firstly, I don’t completely understand your first bullet point from your email yesterday. Why is Section 12-15 not authorized for use within the U.S.?
Secondly, I am confused where the SDS states in Section 14 – Environmental hazards – Marine pollutant: it says “No” but directly under this it says Yes (DOT). What do they mean here?
Then in the Transport/Additional information: it says “not regulated if under 5 L or less for liquids (that’s fine for the 11 oz and 1 gallon product but what about the 5 gallon bucket?
Then again lower, the DOT shows nothing but immediately below it has “Remarks” and it talks about transport labeling is not required for non-bulk package shipments by motor vehicle. Are they talking about just labeling (no fish symbol needed)? Does this mean we do not need to label the 5 gallon buckets? I’m so confused…
I guess I need help in understanding the sequence of the SDS and which requirement I am to follow.
Additionally, I need to determine if the product in 11 oz tubes and 1 gallon tubs are required to have a “Limited Quantity” Label on the package?
Perhaps when you shed more light on the entire subject pertaining to the two SDSs attached, I might be able to understand how you are arriving at what is required and I will be able to apply that to other materials we have.
I could sense he was struggling to understand it all. (I know how he feels).
I can provide some clarification. Please see below.
When the SDS was authorized for use by OSHA in the U.S., it did not include authorization for sections 12-15. Many other countries in the world authorize these sections but we don’t in the U.S. Therefore, I do not rely entirely on the information in sections 12-15 of the SDS. I have found incorrect information there.
I’m not certain either what is meant by the “no” and “yes” in section 14. It appears to me (based solely on section 14) that the manufacturer has identified this as a marine pollutant.
As my article on the Marine Pollutant Exception indicates (see previous email) a marine pollutant in a packaging of less than 5 L / 5 kg is not subject to domestic or international regulations as a marine pollutant.
Separate from the above, solely within the U.S. a marine pollutant in a non-bulk packaging is not subject to any regulation (see my article). That means you can ship it as if it was water.
You are only required to display the limited quantity mark if using the limited quantity exception. The LQ exception may only be used if you have a fully-regulated HazMat. Based on section 14 of the SDS, you do not have a fully-regulated HazMat. The LQ mark is not required.
Please let me know if I can be of any further assistance.
Just one more question:
One other quick question regarding the same products and SDS as we were dealing with earlier.
We sometimes put these on a barge from Seattle to Alaska.
Do we need to fill out the shipping papers, add markings and apply the Misc 9 and fish labels?
I’m sorry this product is so confusing to me.
Thank you.
One more Answer:
Please see below.
Transport by vessel is subject to USDOT and international regulation unless the quantity in a single or combination packaging is less than 5 kg / 5 L.
Some of the packagings you indicated may be below that threshold, others (5 gallon) are not. Therefore, some will be subject to full regulation as a HazMat and some will not.
And that seemed to do it!
That’s awesome!
Thank you again Daniel.
Have a great week!
Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail
The classification of a product offered for transportation to determine if it is a hazardous material, and if yes, what kind. Is the most important responsibility of a HazMat shipper. Only by doing this correctly can the shipper hope to pack, label, mark, prepare a shipping paper, offer placards, provide emergency information, and perform every other regulated function of a HazMat shipper.
I can help you by answering questions and by providing the training required for anyone with a direct affect on the safe transportation of hazardous materials.
Q&A: Can a limited quantity of a hazardous material be transported by air in a non-specification packaging?
A follow-up question from one of my recent Onsite Training customers (11.18.16):
Hello Daniel,
Can you please confirm that a Limited Quantity Air Shipment can go in a non-specification package?
Thank you,
My reply that same day:
Correct.
The IATA regulations at 2.7.1.1 for a limited quantity includes the following:
It is recognized that many dangerous goods can be safely carried in good quality combination packagings which meet the construction requirements of Subsections 6.1 & 6.2 but which have not been marked and tested in accordance with the requirements of 6.0.4.
6.1 = Requirements for inner packagings
6.2 = Specifications for UN Outer Single and Composite Packagings.
6.0.4 = Markings of UN Specification Packagings.
In other words, the packaging must be able to meet the construction requirements of specification packaging but do not have to be tested and marked as such.
Package performance tests for limited quantity packaging by air are documented in 2.7.6 which include a drop test and a stacking test.
I hope this helps.
Please don’t hesitate to contact me with any other questions.
The transportation of a hazardous material (aka: dangerous good) by air – even within the U.S. – will likely be subject to the regulations of the International Air Transport Association (IATA). These regulations are authorized for use within the U.S. by PHMSA/USDOT (at least, the technical instructions of the International Civil Aviation Administration are authorized for use by PHMSA/USDOT and since the IATA Dangerous Goods Regulations are very similar to the ICAO technical instructions and are even a little bit more strict, compliance with IATA results in compliance with ICAO and PHMSA/USDOT. Got it?) and are adhered to by most of the world’s airlines.
Questions like this arise because, while similar in many ways – the regulations of IATA and PHMSA/USDOT differ in several key areas.
Contact me if you have questions about how to ship HazMat by air, highway, rail, or vessel.
Q&A: Segregation of Limited Quantities
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?
I believe you are right, but I’d like a little more information to be certain.
Dan
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:
Thanks. I’m only shipping the Silver Nitrate as the limited quantity with the acid which will be classified as hazardous.
Conclusion/Summary:
Notice from my answer on the 17th that I first determined compliance with the domestic regulations of PHMSA and then those of the International Maritime Organization in the IMDG Code. The transportation to, from, or through the U.S. is subject to the Hazardous Material Regulations of PHMSA. If it will also be shipped internationally – in this case on a vessel – then it will be subject to international regulations as well. Here, the regulations of both PHMSA and the IMO were similar but that may not always be the case.
Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail
It’s not uncommon that person who have received my Onsite Training follow-up with questions once they begin to apply the information from the training on their job.
Contact me to schedule Onsite Training required by the International Maritime Organization (IMO) every three years, the International Air Transport Association (IATA) every two years, or the Pipeline and Hazardous Materials Safety Administration (PHMSA) every three years.
if using the limited quantity exception. The LQ exception may only be used if you have a fully-regulated HazMat. Based on section 14 of the SDS, you do not have a fully-regulated HazMat. The LQ mark is not required.
