Steven Charles Hunt President, ShipMate, Inc. from here to there: topics in transportation Limited Quantities November 2014 SPRAY 31 A couple of weeks ago I received several phone calls from a number of cosmetic manufacturers that were having issues with certain carriers regarding the marking of limited quantities. There appears to be some confusion with respect to the marking of limited quantities by surface, air and ocean, when the “Y” marking is appropriate and when it isn’t, and what size the limited quantity marking must be. I thought I would clarify some of these questions and offer example illustrations of limited quantities for various modes of transport. Limited Quantities 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. Only certain classes and divisions of dangerous goods may be offered as limited quantities. For transport by vessel, the International Maritime Dangerous Goods (IMDG) Code prohibits all Packing Group I dangerous goods from being offered as limited quantities. For transport by air, the International Civil Aviation Organization (ICAO) Technical Instructions further restrict limited quantities to only certain classes and divisions in Packing Groups II and III, and further prohibits certain substances within those classes and divisions from being shipped. Experience has proven that many dangerous goods can be shipped safely in strong outer packaging that is capable of meeting the design, construction and performance tests outlined in the regulatory requirements, but which have not been tested. Thus, limited quantities need not be packaged in expensive UN-performance-oriented packaging that has been tested and marked accordingly. 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. The maximum quantity permitted per inner receptacle (the immediate form of containment) may differ between modes of transportation. For example, a limited quantity of a flammable aerosol is restricted to 1L per can for surface and ocean transport whereas the same product is further restricted to 500mL when offered by air. Size Matters
Spray November 2014
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