By Frits Wybenga, Senior Technical Advisor    September, 2007

PHMSA recently posed a number of questions on a tentative decision by the UN Subcommittee at its July meeting to replace the existing package marking requirement for limited quantities of dangerous goods with a new mark consisting of the letters “LQ”. Opinions on this subject are almost as varied as the products that would be affected themselves. The author seeks to clarify what is currently being proposed, presents a European perspective on the issue and encourages readers to weigh in on this subject.

To formulate their position for the next UN meeting, PHMSA recently posed a number of questions on a tentative decision reached by the July 2007 UN Subcommittee of Experts on the Transport of Dangerous Goods. (Ed. Note: See July/August 2007 issue of HAZMAT Packager & Shipper, Report on UN Decisions by Andy Altemos, p. 13). This was the decision to replace the existing package marking requirement for limited quantities of dangerous goods with a new mark consisting of the letters “LQ” (see UN/SCETDG/31/INF.48 of the UN 31st session).

The UN working group effort was prompted by a paper submitted by the Association of Hazmat Shippers (AHS). Presumably the objective of AHS in making its proposal was to introduce into the UN Model Regulations some of the same regulatory relief provided for consumer commodities, or ORM-D materials, in the DOT Hazardous Materials Regulations (HMR).

The need for further relaxation of requirements for consumer commodities, a subset of limited quantities, is always difficult for the European representatives at the UN to appreciate. This is because under the European road and rail regulations in the ADR and RID, the requirements for limited quantities are already close to the absolute minimum. With packages of limited quantities of dangerous goods only being subject to a marking requirement, it is hard for the Europeans to see any need for further regulatory relief for consumer commodities. With virtually no further possibilities for relaxation under the ADR and RID, it is not surprising that the UN working group arrived at the rather minimal proposal of replacing the existing package marking requirements for limited quantities with a mark consisting of the letters “LQ” surrounded by the square on point diamond.

The working group concluded that delegates should now vet the proposed new marking requirement in their respective countries to determine if this approach would enhance harmonization and would be acceptable from safety and operational perspectives.

The Current State of International Harmonization for Limited Quantity Markings
The current package marking requirements for limited quantities in paragraph 3.4.8 of the UN Model Regulations are fairly recent. They are based on similar marking requirements originally introduced in the ADR/RID (see for example paragraph 3.3.4(c) of the ADR). The UN requirement is for limited quantity packages to bear a mark consisting of the UN number surrounded by a diamond. The ADR/RID requirement is the same except that when the limited quantity package holds more than one item of dangerous goods, the letters “LQ” may be placed in the diamond instead of multiple UN numbers.

Package marking requirements for limited quantities are covered under §172.315 of the HMR. In place of the more common UN number and proper shipping name marking, the internationally required mark consisting of the UN number surrounded by a diamond is permitted.

With the UN marking having been adopted under the HMR as well as the IMDG Code and similar provisions included in the ADR/RID, a single limited quantity mark recognized worldwide could be at hand. ICAO plans to adopt the limited quantity mark in the next edition of the Technical Instructions. Use of the ADR/RID “LQ” mark is not recognized outside of Europe so that international shippers would be advised to stay with the UN number approach even when materials represented by different UN numbers are in the same package.

The HMR provide an alternative marking for limited quantities that meet the definition of consumer commodities. In place of the markings required for limited quantities they may be marked with the letters “ORM-D” and the proper shipping name (see §172.316).  Packages only meeting the ORM-D marking requirement would not be suitable for international transportation as this mark is not recognized outside the US. The regulations do not preclude dual marking so that it is permissible to mark a package with the international limited quantity marking as well as the ORM-D mark. In this way a company would only need a single product inventory to take advantage of the reduced shipping costs generally afforded ORM-D materials in the US while still meeting the international requirements.

The Domestic Benefits of ORM-D over Limited Quantities
Under the HMR, limited quantities are excepted from labeling, performance packaging, segregation requirements and from placarding for rail and highway. But other requirements still apply. Shipping papers are required. In the case of air transport, limited quantity packages are subject to loading and handling restrictions under §175.75.

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