Consumer commodities vs. limited quantities

By John V Currie -- Logistics Management, 4/1/1998

Q: I thought "consumer commodity" shipments were not regulated as hazardous materials, but a container packed with these items was refused by an ocean carrier because it lacked dangerous-goods documents and "limited quantity" container markings. Who's right?

A: There is a difference between a hazardous material described as a "limited quantity" and a hazardous material described as a "consumer commodity." (And yes, a consumer commodity is a hazardous material.)

In domestic transportation, any material listed in Column (2) of the Hazardous Materials Table in 49 CFR may be eligible for an exception as a limited quantity if an entry appears in the corresponding Column (8A). A limited quantity shipment is subject to all of the regulations applicable to that material, except as specified in the exception section.

Once you know your hazardous material qualifies as a limited quantity, you can decide if it may be shipped as a consumer commodity. Does the CFR Section shown in Column (8A) include a paragraph titled "Consumer Commodities"? Is the material a consumer commodity as defined in (section)171.8 of 49 CFR? If the answer to both is yes and the package meets all requirements in the Consumer Commodities section, then the proper shipping name is "Consumer Commodity" and the class is "ORM-D."

Marking and documentation differs for limited quantities and consumer commodities. For "Acetone," Column (8A) shows a limited quantity exception in (section)173.150. That exception provides relief from specification packaging requirements. No placards are required on the transport unit when that material is a limited quantity, and labels are not required for surface transportation. A hazardous-material shipping paper with "Limited Quantity" following the basic description is required.

If that same shipment of acetone is for personal use and it meets 49 CFR (section)173.150(c)'s requirements, the proper shipping name becomes "Consumer Commodity" and the hazard class changes from Class 3 to ORM-D. No shipping paper is required in the United States for surface transportation. A "D" appears in Column (1), meaning that the shipping name "Consumer Commodity" in Column (2) is for domestic transportation only.

When this same shipment moves by sea, it must meet the International Maritime Dangerous Goods Code requirements in Section 18. The IMDG Code allows the package to be marked with either the proper shipping name "Acetone" and the U.N. identification number "UN1090," or with the shipping name "Dangerous Goods in Limited Quantities of Class 3," with no U.N. number required.

No markings are required when that same package contains a limited quantity, is intended for personal care, and is shipped internationally by ocean. But shipping papers are required, and the goods must be described as a limited quantity. A container carrying dangerous goods in only limited quantities does not need placards, but it must be marked "LIMITED QUANTITY."

So, your packages marked "Consumer Commodity, ORM-D" that meet the IMDG Code's definition and packaging requirements for limited quantities must be shown on the shipping papers as a limited quantity and the container must be so marked.

John V. Currie's firm, Currie Associates Inc., provides hazardous-materials transportation safety and compliance audits, consulting services, customized training manuals, and public and in-house seminars. He may be contacted at 1118 Bay Road, Lake George, NY 12845. Phone: (518) 761-0668. Fax: (518) 792-7781. E-mail: currie@netheaven.com.