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.

Before we begin I will disclose that a full explanation of all the details of the Small Quantity Exception is beyond the scope of this one article.  Instead, I’ll summarize the applicability and requirements of the exception and you’ll have to review 49 CFR 173.4 to ensure compliance.

Applicability:

• The use of this exception is restricted solely to domestic transportation (ie entirely within the US and/or its territories).
• Acceptable modes of transportation are by highway or rail only.  For a similar exception available for shipment by air or vessel, refer to:  49 CFR 173.4a  Excepted Quantities.
• Hazardous materials authorized for this exception and maximum quantity limits are identified in Table 1.

Table 1

 Packaging Requirements:

• Specification packaging is not required; however, the following two requirements apply to each inner receptacle except for temperature sensing devices:
1. Must not be liquid-full at 55°C.
2. Is constructed of plastic with a minimum thickness of ≥0.2 mm (0.008 in), or constructed of earthenware, glass, or metal.
• Otherwise, packaging requirements include:
1. If a removable closure, its closure must be held securely in place with wire, tape, or other positive means.
2. Unless equivalent cushioning and absorbent material surrounds the inside packaging, it must be securely packed in an inside packaging with cushioning and absorbent material that will not react chemically with the authorized material and is capable of absorbing the entire contents (if liquid) of the receptacle.
3. The inner receptacle must be securely packed in a strong outer packaging.  This creates what’s known as combination packaging.
4. The completed package must be capable of withstanding tests specified in 49 CFR 173.4(a)(6).
5. The packaging of the material must not result in a violation of 49 CFR 173.21 – Forbidden Materials.  It’s possible that some packaging combinations allowed by this exception may result in a Forbidden Material as identified in §173.21.
6. Gross mass of the completed package (combination packaging) does not exceed 29 kg (64 pounds).
7. Package is not opened or altered until it is no longer in commerce.
8. Outside of the package must be marked by the shipper with the statement:  “This package conforms to 49 CFR 173.4 for domestic highway or rail transport only.”
• The package for a Class 7 – Radioactive material must also conform to §173.421(a)(1-5) or §173.424(a-g), as appropriate.

Miscellaneous:

• An approval is available to allow transportation of the following as long as they comply with all of the other requirements of this section (49 CFR 173.4):
1. A Class 2 Gas other than those identified in Table 1 of this article & 49 CFR 173.4(a).
2. Division 4.2 – Spontaneously Combustible Material (PG I).
3. Division 4.3 Dangerous When Wet Material (PG I).
• Lithium batteries and cells are not eligible for the Small Quantity Exception.
• HazMat Employee training per 49 CFR 172, Subpart H is not required for employees involved only in the transportation of materials in compliance with this part.  In other words:  All Small Quantities = No training (07-0054).

Conclusion:

There you have it, another exception to the HMR.  Perhaps you’re already using this exception or are considering it; in which case this article might have provided critical information.  Perhaps this exception has no application on your shipment of hazardous materials; in that case I hope you at least found this article interesting and have expanded your knowledge of the HMR.

Please don’t hesitate to contact me with any questions about this or other exceptions, or with the general requirements of the HMR for shipping hazardous materials.