October 16, 2020: Don’t Be Fooled by Limited Quantities: Six Myth Busters

Limited quantities of hazardous materials in combination packages – small inner packagings inside of an outer packaging – weighing less than or equal to 30 kg (approximately 66 lbs.) can be exempt from many packaging, marking, and labeling requirements, as well as DOT shipping papers when shipped by ground. Let’s look at several common myths surrounding limited quantities:

Myth #1: Limited quantities are not hazardous materials.

When a shipper determines a material or article meets one or more of the DOT hazard class 1 – 9 criteria, it is a hazardous material. Shipping it as a limited quantity is merely a packaging option.

Myth #2: Employees preparing limited quantity packages do not need DOT training.

Yes, they do! At a minimum, they must have general awareness, function specific, security awareness and safety training. They must receive this training within 90 days of employment (or of becoming a hazmat employee) and be immediately supervised until they receive their initial training. By every 3rd anniversary of their initial training date, they must be re-trained. Training must be properly documented. [See 49 CFR Subpart H for full standards].

Myth #3: All hazardous materials can be shipped as a limited quantity.

No! This is false. To determine if a hazardous material can be shipped as a limited quantity, you must look up its proper shipping name on the §172.101 hazmat table and slide across to column 8A. If you see a number there to complete the regulatory reference §173.***, you will go to that reference and follow the rules laid out for preparing a limited quantity package.

If the word “none” is in column 8A, a limited quantity package is not authorized. Even if you are shipping small amounts in combination packaging, the package must be fully regulated. In that case, you would follow the packaging instructions from column 8B for non-bulk packages.

Myth #4: The quantities of hazardous materials allowed per package are the same by ground, air, and vessel. 

You cannot make this assumption. All three modes of transportation generally limit the gross weight of the package to 30 kg, but the hazardous materials/dangerous goods are limited by quantityper inner packaging, and, in the case of air transportation, the quantityper package as well.

Myth #5: Since limited quantities are not required to be shipped in UN specified packaging, there are no real packaging rules other than weight and quantity limits.

This is not true. If your hazardous material meets the definition of a hazardous substance, hazardous waste, or marine pollutant, the DOT requires shipping papers for ground shipping. (Limited Quantities shipped by air and vessel must always be accompanied by shipping papers.)

  • Packaging effectiveness (e.g., clean, able to withstand conditions normally incident to transportation, keeps hazmat inside)
  • Compatibility
  • Closures for outer and inner packagings (with liquids)
  • Venting
  • Filling limits
  • Securing and cushioning
  • Mixed contents in one outer packaging 

Myth #6: Limited quantities shipped by ground never need shipping papers

This is not true. If your hazardous material meets the definition of a hazardous substance, hazardous waste, or marine pollutant, the DOT requires shipping papers for ground shipping. (Limited Quantities shipped by air and vessel must always be accompanied by shipping papers.)

WHAT CAN STARS DO FOR YOU?

We can create a shipping guide customized for your site and materials. Imagine a colorful reference binder for your employees that includes:

  • The DOT’s basic description for each of your materials (UN ID number, proper shipping name, hazard class and packing group, plus extras such as RQs and technical names)
  • A graphic of authorized limited quantity, non-bulk, and bulk packaging with required marks, labels, and placards
  • Example shipping paper entries for ground, air and/or vessel for each type of package
  • Special packaging instructions
  • Regulatory references for easy look-up if more detailed info is desired.