By Frits Wybenga, Senior Technical Advisor    January, 2007

The UN Committee of Experts on the Transport of Dangerous Goods is coming closer to achieving International Harmonization on limited quantity provisions. In this report Frits Wybenga looks at the progress made in harmonization to date, the remaining issues affecting harmonization, problems that various regulations create, UN solutions, implications for US implementation, and specific caveats from a safety prospective.

The 32nd session of the UN Subcommittee continued its discussion on limited quantities, but no formal papers were submitted. Despite this fact the UN feels that it is coming close to achieving international harmonization. Though there will be benefits, there are still refinements to be made in order to attain complete harmonization.  The following article looks at both the benefits, and the refinements that are still needed.

Harmonization of Limited Quantity Requirements to Date
Considerable work to provide uniform international requirements for limited quantities has taken place over the years.  Relief from labeling, from performance packaging requirements, and from requirements to segregate packages of incompatible materials within a freight container, and a 30 kg gross mass package limit have long been common elements among the various regulations affecting international limited quantity transportation.

More recently the threshold quantity limits for limited quantities of dangerous goods were harmonized.  Except for the air regulations, the same limited quantity inner packaging volume or mass limits are prescribed for each class and packing group level.  Given the more conservative approach by the air mode, no further harmonization in this area is expected. 

Harmonization of the limited quantity package mark has also been accomplished so that a single package mark consisting of a square-on-point with the UN number marked inside (see example) is recognized worldwide.

There are a few caveats in that some regulations allow additional alternatives.  For example, under the HMR either a mark consisting of the UN number and proper shipping name or the square-on-point/UN number mark may be used.   Europe allows the letters “LQ” to be placed in the square-on-point in place of the UN numbers when two or more dangerous goods are present in a single outer package.  Despite some inconsistencies, it is nevertheless possible to mark any limited quantity package with a single mark acceptable throughout the world (i.e., the square-on-point/UN number(s) mark). 

Remaining Harmonization Issues with Limited Quantities
With so much already having been accomplished in harmonizing limited quantity requirements one is bound to ask, “What still needs to be done?”  Answer: harmonization of consumer commodity requirements, particularly package marking and documentation requirements.

The UN Model Regulation limited quantity text is found in paragraph 3.4.9.  It permits limited quantities of dangerous goods for personal or household use packaged in a form intended, or suitable for retail sale (i.e., consumer commodities) to be exempted from package marking, and from the requirements for a transport document.  But this text has not been adopted in its entirety by any of the modal regulations.  Each regulation takes a different approach:

European road and rail regulations (ADR/RID) treat consumer commodities like all other limited quantities, requiring only the limited quantity square-on-point/UN number package mark.  No transport document is required.
The IMDG Code relieves consumer commodities of the package marking requirement, but requires a transport document and marking of freight containers with the words “limited quantities” or “LTD QTY”.
The HMR allows consumer commodities to be marked “ORM-D” and the Consumer Commodity proper shipping name (PSN) in place of the limited quantity mark.  It also exempts consumer commodities from the transport document requirement for rail, highway and vessel transportation.
The ICAO Technical Instructions (or IATA DGR) allow certain consumer products in Class 3, and Division 6.1 and some aerosols to be transported as consumer commodities.  These require a Class 9 label, marking of ID 8000  Consumer Commodity on the package, and a transport document.


Table 1 provides a simplified summary of the various requirements for consumer commodities.  

Problems the Various Regulations Create for the International Shipper of Consumer Commodities
The above analysis portrays a seemingly complex regulatory picture for some of the least innocuous dangerous goods.  But what are the real problems in shipping these materials internationally?  While the comparison portrays a dauntingly complex regulatory maze, the differences boil down to two basic problems.    

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