Steven Charles Hunt President, ShipMate, Inc. from here to there: topics in transportation USPS Regulations perilously out of sync with U.S. DOT Rules A couple of weeks after I wrote an article on the requirements for shipping dangerous goods through the U.S. Postal Service (USPS) for Spray (see Feb. 2014), I had a call from a client that expressed an interest in shipping small (excepted) quantities of dangerous goods through the USPS. I agreed to help them identify and comply with the requirements for these products, but I grossly underestimated the degree of difficulty, not because it is difficult to comply with the rules for the USPS, but because USPS requirements are so antiquated and out of sync with the U.S. Dept. of Transportation’s (DOT) Hazardous Materials Regulations. It’s nearly impossible to comply with both agencies’ requirements without violating the regulations of one or the other. As a result, this client’s shipments have been put on hold temporarily until the USPS makes a decision as to the “mailability” of these products. Postal Service Standards In February’s article, I had stated that “...the standards for Hazardous, Restricted, and Perishable Mail are found in USPS Publication 52. Although the mailing standards for certain hazardous materials in Domestic Mail Manual (DMM) § 601.10 and those found in Publication 52 closely adhere to many of the requirements found in 49 CFR subchapter C....” However, what I have found while working on this particular project for my client is that there is a greater disparity between the requirements than what I had been used to in the past. When reviewing the requirements for small quantities of hazardous materials (having a volumetric capacity of less than 30mL) per inner receptacle, I noticed a fairly major discrepancy with respect to marking between the two sets of requirements. What I have discovered is that USPS regulations are woefully out-of-date and almost completely misaligned with respect to the hazard communication requirements for small, excepted and limited quantities of dangerous goods (a.k.a. hazardous materials). I decided 24 Spray April 2014 to contact the USPS to determine whether I was looking at an older version of its rules, but I was assured that I was looking at the most current set of requirements. When pressed for answers to some rather easy questions regarding harmonization between the two agencies’ requirements, the USPS simply stated that they “...are not the DOT and they have their own rules” and that they would “...update their rules someday, but not anytime soon.” Disharmony To illustrate the disparity between the rules, allow me to describe some of the differences. Small (Excepted) Quantities With respect to small (or excepted quantities), the USPS does not recognize the excepted quantities provisions of 49 CFR 173.4a. The USPS makes reference to small quantities of dangerous goods having a maximum volumetric capacity of 30mL for flammable liquids and requires the use of a mark that states “THIS PACKAGE CONFORMS TO 49 CFR 173.4”. This is clearly a reference to the old DOT requirements that were updated more than four years ago. The DOT eliminated this mark and replaced it with “THIS PACKAGE CONFORMS TO 49 CFR 173.4 FOR SURFACE AND RAIL TRANSPORT ONLY.” The USPS manager I spoke with told me, in no uncertain terms, that the box must be marked “THIS PACKAGE CONFORMS TO 49 CFR 173.4” and will not be permitted to have any other markings on it
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