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.

: Hazard communication required for limited quantity by air.

: Hazard communication required for limited quantity by highway, rail, or vessel.

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

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Conclusion:

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.

Before we begin…

You can read more about the Final Rule here: USDOT/PHMSA Makes Miscellaneous Changes to Hazardous Materials Regulations to Reduce Regulatory Burden

Scope and Applicability:

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:
- International Civil Aviation Organization (ICAO) & International Air Transport Association (IATA)
- International Maritime Organization (IMO)

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Changes to Limited Quantity Exception:

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.

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As a result, the following hazardous materials are now eligible for the limited quantity exception:

Proper Shipping Name (2)	Hazard Class (3)	ID # (4)	PG (5)	Packaging Exceptions (8A)
Allyl isothiocyanate, stabilized	6.1	UN1545	II	153
Aluminum smelting by-products or Aluminum remelting by-products	4.3	UN3170	II	151
			III	151
Amine, liquid, corrosive, flammable, n.o.s. or Polyamines, liquid, corrosive, flammable, n.o.s	8	UN2734	I	None
			II	154
Amyl mercaptan	3	UN1111	II	150
Antimony pentachloride, liquid	8	UN1730	II	154
Antimony pentafluoride	8	UN1732	II	154
Batteries, dry, containing potassium hydroxide solid, electric storage	8	UN3028		154
Borneol	4.1	UN1312	III	151
5-tert-Butyl-2,4,6-trinitro-mxylene or Musk xylene	4.1	UN2956	III	159
1,4-Butynediol	6.1	UN2716	III	153
Calcium resinate	4.1	UN1313	III	151
Calcium resinate, fused	4.1	UN1314	III	151
Camphor, synthetic	4.1	UN2717	III	151
Celluloid, in block, rods, rolls, sheets, tubes, etc., except scrap	4.1	UN2000	III	151
Cerium, slabs, ingots, or rods	4.1	UN1333	II	151
Chloric acid aqueous solution, with not more than 10 percent chloric acid	5.1	UN2626	II	152
1-Chloropropane	3	UN1278	II	150
Chromium trioxide, anhydrous	5.1	UN1463	II	152
Corrosive liquids, flammable, n.o.s.	8	UN2920	I	None
			II	154
Corrosive liquids, oxidizing, n.o.s.	8	UN3093	I	None
			II	154
Corrosive solids, flammable, n.o.s.	8	UN2921	I	None
			II	154
Corrosive solids, oxidizing, n.o.s.	8	UN3084	I	None
			II	154
Corrosive solids, waterreactive, n.o.s.	8	UN3096	I	None
			II	154
Corrosive liquids, oxidizing, n.o.s.	8	UN3093	I	None
			II	154
Corrosive solids, oxidizing, n.o.s.	8	UN3084	I	None
			II	154
Corrosive solids, self-heating, n.o.s.	8	UN3095	I	None
			II	154
Corrosive solids, waterreactive, n.o.s.	8	UN3096	I	None
			II	154
Cyanuric chloride	8	UN2670	II	None
Cyclohexylamine	8	UN2357	II	154
Decaborane	4.1	UN1868	II	151
Detonator assemblies, nonelectric, for blasting	1.4B	UN0361		63(f), 63(g)
Detonators, electric, for blasting	1.4B	UN0255		63(f) 63(g)
Detonators for ammunition	1.4B	UN0365		None
Detonators, non-electric, for blasting	1.4B	UN0267		63(f), 63(g)
Diethyl sulfide	3	UN2375	II	150
2-Diethylaminoethanol	8	UN2686	II	154
N,N-Diethylethylenediamine	8	UN2685	II	154
Diethylthiophosphoryl chloride	8	UN2751	II	154
Difluorophosphoric acid, anhydrous	8	UN1768	II	154
Di-n-butylamine	8	UN2248	II	154
Ethyl bromoacetate	6.1	UN1603	II	153
Fibers or Fabrics impregnated with weakly nitrated nitrocellulose, n.o.s.	4.1	UN1353	III	151
Films, nitrocellulose base, gelatine coated (except scrap)	4.1	UN1324	III	151
Firelighters, solid with flammable liquid	4.1	UN2623	III	151
Flammable solid, oxidizing, n.o.s	4.1	UN3097	II	151
			III	151
Flammable solids, corrosive, organic, n.o.s.	4.1	UN2925	II	151
			III	151
Fluorophosphoric acid anhydrous	8	UN1776	II	154
Fluorosilicic acid	8	UN1778	II	154
Gallium	8	UN2803	III	154
Hafnium powder, wetted with not less than 25 percent water (a visible excess of water must be present) (a) mechanically produced, particle size less than 53 microns; (b) chemically produced, particle size less than 840 microns	4.1	UN1326	II	151
Hexadienes	3	UN2458	II	150
Hexafluorophosphoric acid	8	UN1782	II	154
Hexamethylenediamine solution	8	UN1783	II	154
			III	154
Hydrazine aqueous solution, with more than 37% hydrazine, by mass	8	UN2030	I	None
			II	154
Hydrogen peroxide and peroxyacetic acid mixtures, stabilized with acids, water, and not more than 5 percent peroxyacetic acid	5.1	UN3149	II	152
Hydrogen, peroxide, aqueous solutions with more than 40 percent but not more than 60 percent hydrogen peroxide (stabilized as necessary)	5.1	UN2014	II	152
Hydrogen peroxide, aqueous solutions with not less than 20 percent but not more than 40 percent hydrogen peroxide (stabilized as necessary)	5.1	UN2014	II	152
Hydrogendifluoride, solid, n.o.s.	8	UN1740	II	154
			III	154
Iodine monochloride, solid	8	UN1792	II	154
Lead phosphite, dibasic	4.1	UN2989	II	151
Mercaptans, liquid, flammable, toxic, n.o.s. or Mercaptan mixtures, liquid, flammable, toxic, n.o.s.	3	UN1228	II	150
			III	150
2-Methyl-2-butene	3	UN2460	II	150
Methylal	3	UN1234	II	150
Nitrating acid mixtures spent with not more than 50 percent nitric acid	8	UN1826	II	154
Nitrating acid mixtures with not more than 50 percent nitric acid	8	UN1796	II	154
Nitric acid other than red fuming, with at least 65 percent, but not more than 70 percent nitric acid	8	UN2031	II	154
Nitric acid other than red fuming, with more than 20 percent and less than 65 percent nitric acid	8	UN2031	II	154
Nitric acid other than red fuming with not more than 20 percent nitric acid	8	UN2031	II	154
Octafluorobut-2- ene or Refrigerant gas R 1318	2.2	UN2422		306
Octafluorocyclobutane, or Refrigerant gas RC 318	2.2	UN1976		306
Octafluoropropane or Refriger ant gas R 218	2.2	UN2424		306
Organometallic substance, liquid, water-reactive	4.3	UN3398	I	None
			II	151
			III	151
Organometallic substance, liquid, water-reactive, flammable	4.3	UN3399	I	None
			II	151
			III	151
Organometallic substance, solid, water-reactive, selfheating	4.3	UN3397	I	None
			II	151
			III	151
Oxidizing liquid, corrosive, n.o.s.	5.1	UN3098	I	None
			II	152
			III	152
Oxidizing solid, water reactive, n.o.s.	5.1	UN3121	I	None
			II	152
Perchloric acid with not more than 50 percent acid by mass	8	UN1802	II	154
Peroxides, inorganic, n.o.s. 5	5.1	UN1483	II	152
			III	152
Phosphorus heptasulfide, free from yellow or white phosphorus	4.1	UN1339	II	151
Phosphorus, amorphous	4.1	UN1338	III	151
Phosphorus oxybromide	8	UN1939	II	154
Phosphorus pentachloride	8	UN1806	II	154
Phosphorus sesquisulfide, free from yellow or white phosphorus	4.1	UN1341	II	151
Phosphorus tribromide	8	UN1808	II	154
Phosphorus trisulfide, free from yellow or white phosphorus	4.1	UN1343	II	151
Propionitrile	3	UN2404	II	150
1,2-Propylenediamine	8	UN2258	II	154
Pyridine	3	UN1282	II	150
Silicon powder, amorphous	4.1	UN1346	III	151
Sludge, acid	8	UN1906	II	154
Sodium chlorite	5.1	UN1496	II	152
Sulfur	4.1	UN1350	III	151
Sulfuric acid, spent	8	UN1832	II	154
Tetrafluoromethane or Refrigerant gas R 14	2.2	UN1982		306
Tetrahydrofuran	3	UN2056	II	150
Thiophosphoryl chloride 8	8	UN1837	II	154
Titanium hydride	4.1	UN1871	II	151
Titanium powder, wetted with not less than 25 percent water (a visible excess of water must be present) (a) mechanically produced, particle size less than 53 microns; (b) chemically produced, particle size less than 840 microns	4.1	UN1352	II	151
Titanium sponge granules or Titanium sponge powders	4.1	UN2878	III	151
Toxic liquids, water-reactive, n.o.s	6.1	UN3123	I	None
			II	153
Toxins, extracted from living sources, liquid, n.o.s.	6.1	UN3172	I	None
			II	153
			III	153
Toxins, extracted from living sources, solid, n.o.s.	6.1	UN3462	I	None
.			II	153
			III	153
Toxins, extracted from living sources, solid, n.o.s	6.1	UN3462	I	None
			II	153
			III	153
Triallylamine	3	UN2610	III	150
Water-reactive liquid, corrosive, n.o.s.	4.3	UN3129	I	None
			II	151
			III	151
Water-reactive liquid, n.o.s.	4.3	UN3148	I	None
			II	151
			III	151
Water-reactive liquid, toxic, n.o.s.	4.3	UN3130	I	None
			II	151
			III	151
Water-reactive, solid, oxidizing, n.o.s.	4.3	UN3133	II	151
			III	151
Zinc ammonium nitrite	5.1	UN1512	II	152
Zinc chloride, anhydrous	8	UN2331	III	154
Zirconium hydride	4.1	UN1437	II	151
Zirconium powder, wetted with not less than 25 percent water (a visible excess of water must be present) (a) mechanically produced, particle size less than 53 microns; (b) chemically produced, particle size less than 840 microns	4.1	UN1358	II	151
Zirconium suspended in a liquid	3	UN1308	I	None
			II	150
			III	150

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Conclusion:

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… Section 14 of SDS for Marine Pollutant

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).

Daniels Training Services, Inc.

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In sum:

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.

Thank you again for all your help Daniel.

Looking forward to your response.

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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.

Vessel or barge transporting HazMat

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

International and Domestic

Daniels Training Services, Inc.

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/

Conclusion:

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.

Daniels Training Services, Inc.

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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.

Non-bulk packaging of HazMat - Limited Quantity

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

International and Domestic

Daniels Training Services

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/

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.

The Description of a Limited Quantity of a Hazardous Material on a Shipping Paper

Some Changes to the Hazardous Material Regulations for 2013

It seems that as soon as you understand the regulations they change it. And that’s the case with several aspects of the Hazardous Material Regulations (HMR) that are scheduled to change as of this December 31st. This list does not attempt be be all-inclusive but it does summarize the big changes to the HMR to watch for in the new year.

Change in the order of the basic description. After 12.31.12, the only acceptable order for the basic description when describing a hazardous material is: (1) Identification Number, (2) Proper Shipping Name, (3) Hazard Class, and (4) Packing Group. The old order, and still acceptable until 12.31.12, but not after is: (1) Proper Shipping Name, (2) Hazard Class, (3) Identification Number and (4) Packing Group. Notice that the Identification Number has been moved from 3rd to 1st in the order of the Basic Description, this was done to align domestic regulations with international and to make the Identification Number, which plays a key role in emergency response, more visible.

The order of the Basic Description acceptable only until 12.31.12:

The order of the Basic Description that must be used as of 1.1.13:

End of Consumer Commodity shipments as an ORM-D by air. As part of its long-term phase out of the Consumer Commodity exception and the ORM-D hazard class, 12.31.12 is the deadline for use of this exception for shipments of hazardous materials by air. After this date a hazardous material that meets the definition of a Consumer Commodity and is to be transported by air must either be shipped according to the new Limited Quantity rules, or as a hazardous material subject to the full HMR. The purpose of this change is to align domestic and international regulations, since the Consumer Commodity Exception is not recognized in international transportation. The revision was designed to minimize the impact on shippers of Consumer Commodities, so it is likely that any HazMat you are currently shipping as a Consumer Commodity will be applicable for the Limited Quantity Exception which, other than its marking, differs little from the current Consumer Commodity Exception. Hazardous materials may continue to use the Consumer Commodity exception for shipments by ground or vessel until 12.31.13 (US DOT has requested an extension of this date to 12.31.15).

End of the Limited Quantity marking for shipments by air. Along with the phase-0ut of the Consumer Commodity Exception referenced above the current Limited Quantity marking is being revised as of 12.31.12 to come into alignment with international regulations. After 12.31.12 the current Limited Quantity marking will no longer be acceptable for shipments by air of a hazardous material using the Limited Quantity Exception. Other changes to the regulation may affect other aspects of your Limited Quantity shipment as well.

End of the “Danger” label for shipments of HazMat forbidden from transport in passenger aircraft. The purpose of this label is to alert shipping personnel to hazardous material packages that can not be loaded on a passenger carrying aircraft; they are required by IATA, ICAO, and US DOT regulations. The change (mandatory after 12.31.12) is being made to provide a better warning to HazMat Employees who may handle these packages.

Old label, valid until 12.31.12:

New label, must be used as of 1.1.13:

I’m sure there’s more, but these are the big ones I’m familiar with. Please feel free to contact me if you are aware of any impending changes to the regulations or have any question about how these changes may affect you. My training is a great way to learn the HazMat regulations and to get your questions answered. I also provide training for Hazardous Waste Personnel required by the US EPA.

Question (11.23.21):

Answer (11.23.21):

Conclusion:

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Before we begin…

Scope and Applicability:

Changes to Limited Quantity Exception:

Conclusion:

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A question June 16, 2020:

My reply the same day:

He still had questions, so the next day:

I could sense he was struggling to understand it all. (I know how he feels).

Just one more question:

One more Answer:

And that seemed to do it!

Conclusion:

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A question from a customer of my ONSITE TRAINING on October 15th, 2015:

(10.15.15) I was certain he was right about the segregation requirements for a Limited Quantity but I wanted a little more information:

And the next day (10.16.15) I got it:

With that information I replied with “The Big Answer” on October 17th:

His final reply:

Conclusion/Summary:

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