By Gordon Rousseau, Senior Technical Advisor    November, 2007

The Hazardous Materials Table in § 172.101) may not offer the only choice for shippers seeking to define packaging authorizations and requirements for a particular product in the 49 CFR. Not to be overlooked, and among the many options available to small quantity shippers are the Small Quantity Exceptions, Materials of Trade Exceptions, Limited Quantity Exceptions, and Consumer Commodities Exceptions.

Ed. Note: This article does not address explosives and limits itself primarily to domestic shipping considerations.

The transportation of hazardous materials (hazmat) in small quantities often raises questions when applying the DOT Hazardous Materials Regulations (HMR). Are shipments of hazardous materials in quantities of a couple of ounces, of 10 or 20 grams, for example, regulated by DOT? What about shipping an ounce, a pint, half a liter? Frustration often increases when searching for the answers in the DOT Hazardous Materials Regulations (49 CFR Parts 100-185).
 
Hazmat professionals usually attend hazmat training early in their career. Subjects discussed are unfamiliar to the newcomer and become lost in the volume of information to be quickly absorbed in the classroom. Later, the stress of a daily shipping routine blurs what was learned during hazmat training. Forgotten are the numerous DOT regulations that offer alternative means of shipment, especially for small quantities. 

The Hazardous Materials Regulations Are Flexible
The DOT Hazardous Materials Regulations are not as rigid as they initially seem. Many forget that these regulations are filled with options for selecting which regulation should apply to a shipment. The correspondence that DOT receives questioning the rules governing small shipments demonstrates these oversights.

In the workplace, too many shippers search the DOT regulations by simply looking up the product in the Hazardous Materials Table (§ 172.101). Then, by using the section references in this table, they proceed directly to the reference shown for what they believe to be THE requirement. It often is not the only choice.

For example, elsewhere the DOT regulations provide special packaging and shipping alternatives for very small quantities, e.g., 1 ounce or 30 mL of a material (§ 173.4), and for intermediate quantities. They provide relief for materials used in agricultural operations (§ 173.5), for oilfield operations and vehicles (§ 173.5a), and for materials transported to protect the health and safety of operators or passengers, transported for the maintenance or operation of a vehicle, or transported to support a principal business, the so-called Materials of Trade (MOTs) (§§ 171.8 and 173.6). While some of the quantities authorized are limited, some of the alternatives go well beyond small quantities. In other examples, some classifications contain helpful variations for part of the class, e.g., flammable liquids that have a flashpoint of 100°F or above (§§ 173.120 and 173.150). These may be re-classed as combustible liquids, and the typical detailed non-bulk and bulk packaging specification requirements need not be applied.

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