December 2014 SPRAY 29 A quick search of the placarding requirements in 49 CFR Part 172, subpart F, §172.500 reveals that the “placarding” requirements do not apply to limited quantities and Consumer Commodities. See next page: §172.500 Applicability of placarding requirements (a) Each person who offers for transportation or transports any hazardous material subject to this subchapter shall comply with the applicable placarding requirements of this subpart. (b) This subpart does not apply to — (1) Infectious substances; (2) Hazardous materials classed as ORM-D; (3) Hazardous materials authorized by this subchapter to be offered for transportation as a limited quantity when identified as such on a shipping paper in accordance with §172.203(b) or when marked as such in accordance with §172.315. (4) Hazardous materials prepared in accordance with §173.13 of this subchapter; (5) Hazardous materials which are packaged as small quantities under the provisions of §§173.4, 173.4a, 173.4b of this subchapter; and (6) Combustible liquids in non-bulk packaging. Costly Misconceptions Because of this very simple misunderstanding, manufacturers of aerosols or other limited quantities may subject themselves to costly surcharges that need not be applied and the carrier may risk losing a very lucrative account because it was overcharging the customer. Therefore, manufacturers and carriers alike are encouraged to communicate clearly to one another the products that are being carried for transportation in commerce. A clear description of the goods, as well as explanation of the packaging, marking, labeling and documentation may help both parties avoid an ugly situation. I often counsel my shipping clients to host an annual carrier conference whereby their transportation partners are encouraged to attend and openly discuss the regulatory requirements for the carriage and security of the goods they are entrusted to carry. It is an excellent opportunity to build a mutually beneficial relationship and to ensure that all parties are on the same page and have the same understanding. Differences in interpretation can easily be ironed out and tensions thereby relieved. For additional information on limited quantity markings or the carriage of dangerous goods by any mode or in any quantity, visit the DOT PHMSA website at http://phmsa.dot.gov/hazmat or call ShipMate, Inc. at (310) 370-3600. SPRAY
Spray Dec 2014
To see the actual publication please follow the link above