By Prokopis A. Christou, PE
Did you know that the U.S. Department of Transportation (DOT) Hazardous Materials Regulations regulations provide exceptions from some of its requirements? Here is a list of the most frequently used exceptions:
List of Hazardous Materials Regulations Exceptions Guidance The Hazardous Materials regulations, which affect the shipping of DOT Hazmats, provide relief from its requirements in certain situations--mostly for smaller quantities of lower risk materials. Below is an explanation of the most frequently used exceptions. Of course, taking advantage of exceptions is not mandatory.
Excepts certain hazardous materials from the hazardous materials regulations if they qualify and comply with 173.4.
Materials: Class 3, 7, 8 and 9, Div. 4.1, Div. 4.2 (PG II, PG III), Div. 4.3 (PG II, PG III), Div 5.1, 5.2, 6.1
Quantity Limits: Inner receptacle maximum quantity: Not more than 30 ml (l ounce) for liquids. Not more than 30 g (l ounce) for solids 1 g (0.04 ounce) for Div 6.1, PG I Less than activity thresholds for radioactives Gross mass of completed package not more than 64 Kg
Special requirements: Drop test and stacking test for sample package. Certification marking on package for conformance with 173.4.
Details: See 49 CFR 173.4
Excepts materials of trade carried on motor vehicles from the hazardous materials regulations if they qualify and comply with 173.6.
Materials: Class 3, 8, 9, Div 4.1, 5.1, 5.2, 6.1 or ORM-D, Div 2.1 or 2.2, Div 4.3 (PG II or III). Examples of these materials include paint, paint thinner, gasoline, muriatic acid, battery fluid, drain cleaners, self inflating life boats, acetone, propane, oxygen, nitrogen, charcoal, test kits, bleaching compounds, benzoyl peroxide, pesticides, hair pray, spray paint.
Quantity Limits: Vary by class/division. In general, maximum aggregate gross weight of 200 Kg (440 lb) for all MOT materials.
Special Requirements: Applicable only to materials that meet the definition of Material of Trade Requirements for packaging and hazard communication
Details: See 49 CFR 173.6 and 49 CFR 173.8 material of trade definition.
Excepts certain materials from labeling and placarding if they quality and comply with 173.13.
Materials: Class 3, 8, or 9 or Div 4.1, 4.2, 4.3, 5.1, or 6.1.
Quantity Limits: Not more than four intermediate packages in an outer package. Not more than 1.2 liters per inner packaging for liquids. Not more than 2.85 Kg (6.25 lb) per intermediate packaging.
Special Requirements: Modal restrictions Special packaging requirements Certification marking on package for conformance with 173.13
Details: See 49 CFR 173.13
Excepts certain materials from labeling (unless by air), specification packaging, and placarding if they qualify and comply with requirements. Slight variations exist depending on the material.
Materials: Only for materials for which column 8A of the Hazardous Materials Table notes the exception by reference to the section that allows the exception. The exceptions are found at 173.150 through 173.156 and 173.306. Materials include Class 3, 8, 9, ORM-D, Div 4.1, 4.3, 5.1, 6.1.
Quantity Limits: Inside quantity limits vary by material In general, maximum gross weight not more than 30 Kg (66 lb) per completed package.
Special Requirements: Applicable only to materials for which column 8A cites the exception. Restrictions for air shipments may apply.
Details: See Hazardous Materials Table, Column 8A and referenced section.
Excepts certain materials from labeling, specification packaging, placarding, and shipping papers if they qualify and comply with requirements. Slight variations exist depending on the material.
Materials: Only for materials which column 8A of the Hazardous Materials Table notes the exception by reference to the section that allows the exception. Materials must meet the requirements for limited quantity and the definition of Consumer Commodity (see 171.8)
Quantity Limits: Same as for limited quantity exceptions. Additional allowances for certain exclusive shipments by rail or motor carrier
Special Requirements: Material is renamed "consumer commodity" and re-classed as ORM-D material ORM-D marking on package Exceptions not allowed for air shipments, hazardous waste, hazardous substances, or marine pollutants.
Details: See Hazardous Materials Table, column 8A and referenced section F. Other Exceptions · 173.5 Agricultural operations · 173.7 Government material More information Regulations: 49 CFR as cited
About the Author
Prokopis Christou, P.E. has 14 years of diverse experience in managerial,
technical, and teaching responsibilities in environmental, safety,
transportation, regulatory, and engineering matters. Email: prokopis@hotmail.com