small quantity exception

Q&A: Can this HazMat be transported under the Small Quantity Exception?

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):Small quantity exception package mark

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.

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:

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.

Q&A: What’s the difference between DOT’s small quantity exception and the limited quantity exception?

A question I received October 31, 2017 through the Contact me form on my website:

Subject: Domestic ground: small quantity exception 173.4 vs limited quantity

Hi Daniel,
I have found your website very helpful. I am wondering if you could expand on your discussion of the small quantity exceptions of 173.4 (https://danielstraining.com/what-is-the-small-quantity-exception-to-the-hmr/) and discuss how it compares with limited quantity. Especially within the United States, since FedEx (and I assume other carriers) does not charge a hazardous materials fee for limited quantity by ground. So, in that situation, which is preferable and why – 173.4 or limited?
Thank you for your consideration,

I was able to reply immediately:

Thank you for contacting me.

I will research your question and reply.

If you like this article, please share it using any of the social media platforms identified at the bottom of this article.

You’ll look real smart recommending my articles!

And by November 1st I had an answer for him:

Limited Quantity in strong outer packaging

A hazardous material packaged as a limited quantity.

I will try to answer your question below. I will be able to provide more helpful information if you provide a more specific question.

  • The small quantity exception is for use only within the U.S. whereas the limited quantity exception is accepted in international transport.
  • The small quantity exception is for use only in transport by highway or rail whereas the limited quantity exception is available by all modes (highway, rail, air, vessel).
  • The small quantity exception is limited to a net quantity of 30 ml / 30 g for most HazMat and 1 g for others. The gross mass for a package of a small quantity must be no more than 29 kg. The net quantity limit for a limited quantity varies by HazMat but can be much higher. The gross mass for a limited quantity package is 30 kg.
  • The big advantage to the small quantity exception, if the above limitations can be met, is that besides the requirements of the exception the HazMat packaged as a small quantity is not subject to any of the Hazardous Materials Regulations of PHMSA/USDOT.
  • HazMat shipped as a limited quantity is excepted from a lot of the HMR – notably the need for specification packaging – but the following remain:
    • Limited quantity mark.
    • Orientation arrows if liquid.
    • Shipping paper, unless by ground.
    • HazMat labels and other package marks if by air.
  • While the small quantity is excepted from all of the HMR the limited quantity is not. Therefore, when shipping a small quantity only the personnel involved in its classification would require HazMat Employee training; those involved in the packing, loading, & transport will not require training.  However, a limited quantity is not excepted from the training requirements and therefore all employees involved in its transport must receive HazMat Employee training.

I hope this helps.

Please contact me with any other questions.

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/

It looks like my information was helpful to him:

Hi Daniel,
I appreciate the very informative response. Based on the key differences you mentioned, I have just started to implement small quantity exemption and have discovered many products that we previously shipped as limited quantity ground are eligible. Thank you!
Best regards,

Small quantity exception package mark

A hazardous material packaged as a small quantity.

Conclusion:

I find this type of engagement very satisfying.  Some person out there – not a customer – has a good level of knowledge about the Hazardous Materials Regulations but needed some guidance and I was there to provide it.  In this situation it appears that my information will help this HazMat shipper to save money on shipping costs while maintaining HazMat transportation safety.

What is the Small Quantity Exception to the HMR?

The transportation of a hazardous material (HazMat) is subject to the Hazardous Material Regulations (HMR) of the PHMSA/USDOT.  This includes but is not limited to the following:

  • Classification of the HazMat.
  • Selection and use of specification packaging.
  • Application of the four hazard communication methods.
  • HazMat Incident Reporting.
  • Load securement and segregation.
  • Registration as a shipper or carrier of HazMat.
  • Training of HazMat Employees.

However, exceptions to the HMR exist; their purpose is to allow the safe transportation in commerce of certain hazardous materials without the full regulatory burden.  These exceptions, however, come with requirements of their own which you must be aware of if you are to make use of them.  One of these exceptions to the HMR, the Small Quantity Exception, will be explained in this article.

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