Retroactively effective to 1/1/2013, for other than transportation by aircraft (highway, rail, vessel), PHMSA has extended authorization of the ORM-D classification and packages marked as “Consumer Commodity, ORM-D” to December 31, 2020, which is far beyond what they originally proposed in early 2012.
Also effective retroactively to 1/1/2013, PHMSA has extended the use of the white square-on-point for limited quantity (LTD QTY) packages for other than air transportation (highway, rail, vessel) until January 1, 2015. After such time, the “blank” black and white mark will be required.
This final rulemaking also includes relief for limited quantities with regards to incident reporting requirements. With the eventual dissolution of ORM-Ds, PHMSA has also decided to permit materials packaged as LTD QTY to be eligible for the Material of Trade exception.
In response to appeals of HM-213 regarding maintaining package manufacturer notifications including closing instructions, PHMSA has reverted to their original requirement to retain these records 365 days. Only bulk packages and cylinders which have these instructions permanently embossed on each packaged will be exempted from these retention requirements.