Limited Quantities and Consumer Commodities
The ORM-D classification and the “consumer commodity” proper shipping name are in the process of being eliminated from the DOT Hazardous Materials Regulations. They will no longer be authorized as of January 1, 2014. Materials previously meeting the definition of a consumer commodity will be required to be shipped as limited quantities.
As part of these changes, shipping papers will no longer be required for ground shipments of limited quantities, unless they are also a hazardous substance, a hazardous waste or a marine pollutant. Shipping papers continue to be required for air and vessel shipments.
Prior to January 1, 2014, either the new limited quantity requirements or the old limited quantity and ORM-D requirements may be used.
A “limited quantity” or “LTD QTY” notation is still required on documentation for ocean shipments, but this notation is no longer required on the Shipper’s Declaration for Dangerous Goods for air shipments. Packages shipped by air are no longer required to be marked with the words “Limited Quantity” or “Ltd Qty”.
Also as part of these changes, a new limited quantity marking (100 mm x 100 mm) will be required for all modes of transportation.
For limited quantity shipments by ground or water, a diamond with black triangles in the top and bottom corners will be required. Ground and water shipments are not required to be marked with the proper shipping name, identification number or to display hazard labels (except if toxic).
For limited quantity shipments by air, a diamond with black triangles in the top and bottom corners plus the letter “Y” in the center is required (Item # W39-546). This label is already mandatory under the IATA Dangerous Goods Regulations. Limited quantity shipments by air must display hazard labels, be marked with the proper shipping name and identification number in addition to the new limited quantity marking.
Cargo transport units containing dangerous goods in only limited quantities being shipped under the IMDG Code must be marked with large (250 mm x 250 mm) limited quantity marks on all four sides.
Following are limited quantity requirements which are in the process of being ELIMINATED by January 14, 2014:
- Packagings containing limited quantities of hazardous materials need not be marked with the proper shipping name, but must be marked with the identification (ID) number, preceded by the letters "UN" or "NA," as applicable, and placed within a diamond.
- The ID number marking must be applied on at least one side or one end of the outer packaging of a size relative to the packaging that is readily visible. The line forming the diamond must be at least 2 mm wide and the ID number must be at least 6 mm high.
- If hazardous materials with different ID numbers are contained in the same package, the package must be marked with either individual diamonds bearing a single ID number, or a single diamond large enough to include each applicable ID number. This requirement is optional (i.e., packages may continue to be marked with the proper shipping name for ground shipments instead of the ID number marking).
A new employee handling dangerous goods needs to be trained within ninety days of their start date. Recertification is required a minimum of every three years (or as regulations change) for DOT and IMO, and every two years (or as regulations change) for IATA. The best and most efficient way to do this is through one of our two-day Multi Modal training seminars. For more information, check our website, download a .pdf brochure, or call 800-631-3098.
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