Steven Charles Hunt President, ShipMate, Inc. Limited Quantities 26 Spray December 2014 from here to there: topics in transportation Costly Misconceptions Shortly after I drafted last month’s article, Limited Quantities— Size Matters, I received a phone call from a very large cosmetic manufacturer in Los Angeles, CA. Even though this company ships hundreds of millions of dollars in freight annually, they were having issues with their carriers with respect to the placarding of freight containers that were being drayed to the port for carriage aboard cargo ships bound for various international destinations. After a lengthy interview with the International Logistics Coordinator, it appears that the carrier was charging the manufacturer exorbitant freight surcharges because of the carrier’s misconception that the container was required to be “placarded” with the hollow diamond with black points. Limited Quantities As I stated in last month’s article, a “…limited quantity of a hazardous material means the maximum amount of a hazardous material for which there is a specific labeling or packaging exception. Whether or not a hazardous material may be shipped as a limited quantity is dependent upon the following factors: (a) the hazard class and division for the substance or article; (b) the size of the inner receptacle; and (c) the total gross mass of the completed package… “There are also certain economic advantages to shipping a hazardous material as a limited quantity, including reduced hazard communication requirements for surface and ocean transport, and an exception from the shipping paper requirements for surface transport. Additionally, many carriers have reduced shipping rates or surcharges for limited quantities compared to fully-regulated dangerous goods shipments.” Obviously, in this case, the carrier, as well-intentioned as it might be, is apparently charging the manufacturer costly hazardous materials surcharges because they dispatch only drivers that have a Hazardous Materials Endorsement to the Commercial Drivers’ License (CDL). Nomenclature Although the enlarged Limited Quantity Marking applied to the four sides of an intermodal freight container have dimensions identical to the hazard-warning placards applied for international ocean shipments (250 mm x 250 mm), the Limited Quantity Marking is not a “placard” as most people erroneously assume. The U.S. Dept. of Transportation (DOT) has a number of “reserved” terms including “labels,” “placards,” “markings,” “marks” and “panels,” all of which help to communicate the risks associated with dangerous goods. The term “labels” refers to the hazard warning signs applied to packages of hazardous materials such as drums, boxes, bags and cylinders. “Labels” can also mean “cargo handling labels,” such as the orientation arrows that indicate that liquids are contained within a combination packaging and should be stored and handled in an upright position. Labels are typically 100mm x 100mm and applied to a package in a diamond (or square-on-point) configuration. Interestingly enough, there is no regulatory requirement in the U.S. that the hazard warning labels be applied to a package in a diamond configuration; this is another common misconception. However, there is such a regulatory requirement in Canada. “Placards” are “enlarged labels” applied to cargo transport units e.g., freight containers, cargo tanks, rail cars, trailers and bulk packaging (such as ISO tank containers, Intermediate Bulk Containers, “totes” and “supersacks”). Unlike labels, placards must be applied to the exterior surfaces of the cargo transport unit or bulk packaging in a diamond (or square-onpoint) configuration and in such a manner to promote visibility, e.g., at least five feet in from the corner post and five feet up from the bottom rail of an intermodal freight container. A “mark” or “marking” is neither a label nor a placard but rather another form used to communicate special warnings or information associated with the products being carried. The term “mark” or “marking” may refer to a UN specification packaging marking or DOT mark applied Hazard warning label Cargo handling label Placard
Spray Dec 2014
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