Go Small
Limited, Small and Excepted, I always encourage anyone who will listen, to take one of these exceptions when shipping hazardous materials or waste. Any time you can be “excepted” from the use of hazmat shipping papers, labels, marks, placards, emergency response information, DOT/UN containers, the 4 levels of training and the employee testing requirements, “Do it!”
LIMITED
Limited Quantities would be the first one for my clients who don’t like to fill out hazmat shipping papers, (i.e., no hazardous material endorsement signatures), which are assigned in column 8(A) of the 49 CFR Department of Transportation 172.101 Hazardous Materials Table. No UN/DOT containers, labels, vehicle placards or emergency response information and the best part no hazmat shipping papers, only manifests for waste.
Shippers and waste generators must display the “Limited Quantity Mark” on each package and train and test to all 4 levels under Part 172.700, but considering the lack of full regulatory compliance, the training documentation would be the biggest part of your regulatory responsibilities.
The shipping names “Acetone”, “Paint” and “Flammable Liquid N.O.S.”, all display the 173.150 exception in the Hazardous Materials Table. This would authorize Limited quantity ground containers of up to 30 kilograms each in combination non spec containers with up to 1 liter inner receptacles with just the limited quantity mark and the training requirements for these flammable liquids when in packaging group II. And for products like Flammable Paint or even Waste Paint it could up the inner packaging to 1 gallon because of the 172.102 Special provision 149 in column 7 of the Hazmat table.
There is even a provision in 173.25(b) to use shrinkwrap as the outer packaging, which can be a game changer when disposing of small containers of hazardous waste. This would be my preference instead of using the Section 173.12 Lab packs in certain cases.
SMALL
Small quantities are next on my list which would exempt you from all the Department of Transportation Hazardous Material Regulations, if you mark the lightly tested containers (up to 30 kilograms each) with the statement “This package conforms to 49 CFR 173.4 for domestic highway or rail transport only.”
However, the maximum quantity of material per inner receptacle or article is limited to Thirty (30) mL (1 ounce) for liquids and gases, Thirty (30) g (1 ounce) for solid materials.
EXCEPTED
Excepted quantities would be last, but not least, on my list because of the benefits of this exception in the air mode (no shippers declaration). Of course, the total inner container amounts would be the smallest yet, with outer packaging aggregate quantity limits up to 1 kg (2.2 pounds) for solids or 1 L (0.2 gallons) for liquids and for Division 2.2 material, up to 1 L (61 cubic inches) or less.
And with a maximum quantity for inner receptacles of up to 30 g (1 ounce) or 30 mL (1 ounce) for solids or liquids and for gases a water capacity of 30 mL (1.8 cubic inches) or less , and only minimal non UN packaging testing requirements when the combination containers display the “Excepted Quantity Mark” bearing the hazard class number and the name of the shipper or consignee if not shown elsewhere on the package.
You should really try to take these exceptions whenever you can, or give us a call and we can do it together.
Robert J Keegan
Publisher and President
Hazardous Materials Publishing Company
hazmat.tsp@gmail.com
