Custom-Pak box markings changing from ORM-D to LTD QTYCustom-Pak Products
HOW does this affect my company?
- If your company does NOT re-ship products received from Custom-Pak, these changes will have minimal impact.
- If your company DOES re-ship the products you receive from Custom-Pak, please carefully read this information and share it with others at your company who are involved with the shipping and handling of these products!
WHAT? The shipping classification ORM-D/Consumer Commodity is being phased out by the Department of Transportation (DOT). On January 19, 2011, the DOT’s PHMSA division published final rule HM-215K which will eventually eliminate the ORM-D/Consumer Commodity shipping classification. Based on recommendations from trainers and carriers alike, Custom-Pak has chosen to phase in early compliance beginning now rather than wait until the last possible moment.
WHY? To align U.S. shipping regulations with international shipping regulations so there is a smoother flow of goods through global commerce — major carton re-marking should no longer have to be done for products being shipped from USA to other countries. Traditionally the USA’s definition of Limited Quantities and Consumer Commodities has been quite different from international standards. So after years of international pressure, PHMSA finally agreed to eliminate the ORM-D classification for global harmonization reasons. HM-215K simplifies the number of options available to the shipper and makes Limited Quantity (LQ or LTD QTY) the closest alternative to ORM-D to ship products economically and efficiently. Materials which were previously transported as ORM-D should instead be able to be transported as LQs and be granted substantial relief from hazmat regulations, similar to ORM-D.
GROUND SHIPPING DETAILS:
For LQ ground transportation of small parcel shipments with carriers like FedEx &UPS, under the new LQ regulations:
- It is our understanding that small parcel carriers will process LQ labeled packages similar to ORM-D. Custom-Pak has spoken to FedEx & UPS representatives and they have confirmed that hazmat surcharges will not apply.
- Each LQ ground package must display the LQ diamond symbol (see diagram below) rather than the Proper Shipping Name and/or Identification Number which the old LQ shipping method had required. This means that ground packages of all non-toxic LQ hazmat products are labeled identically. See §172.315 for details and below example of properly labeled LQ ground package:
For ground transportation of larger shipments via common carrier/truck line, under the new LQ regulations:
- Packages will require the same markings as in the picture above.
- Transportation vehicles will NOT require placarding for LQ shipments. Also note that LQ shipment’s weight should not be counted when calculating weight for placarding requirements, so this means that LQs can be >1000# total and still not need placards — see 172.500(b)(3) for details.
- If your company uses shipping papers such as Bills of Lading, note that the description must be changed from ORM-D Consumer Commodity to the actual product description in this format: UN I.D. #, Proper Shipping Name, Hazard Class, Packing Group, and followed by the words “Limited Quantity” or LTD QTY. Examples include:
- UN1950, AEROSOLS, FLAMMABLE, 2.1, LTD QTY (most aerosol coatings use this description)
- UN1263, PAINT, 3, II, LIMITED QUANTITY (most liquid coatings packaged in small containers up to and including 32 fl. oz. quart size use this description)
- UN1219, ISOPROPANOL SOLUTION, 3, II, LTD QTY (our GAP-4 Glass Adhesion Promoter would use this)
Also note that the HM (HazMat) column must be checked on Bills of Lading for LQ shipments. However this does not necessarily mean that a hazmat fee will be assessed since often times truck line carriers align their ground shipping policies with the major parcel carriers — check with your truck line carrier regarding this. In principle, because the shipment does not require placarding or special handling they should not assess a HazMat fee, but in the end it is up to the policies of the individual carrier. For example, Custom-Pak uses a couple small truck line carriers for WI & IL shipments and neither of them assess hazmat fees for LQ or regular hazmat. If truck line carriers do assess a hazmat fee, it will usually be quite nominal ranging from $10-$20 for most nationwide carriers.
AIR SHIPPING DETAILS:
For LQ air shipments of small parcel shipments via FedEx (note that Custom-Pak only uses FedEx for hazmat air shipments), see the various requirements in IATA’s most recent Dangerous Goods Regulations (DGR) book. Note that:
- For non-UN spec packaging a similar LTD QTY diamond symbol is used as ground except it has a “Y” in the center which denotes Air transport — see IATA’s DGR 18.104.22.168 for details and below for examples of properly labeled LQ Flammable Gas aerosols and Flammable Liquid paint packages:
Shipping papers are still required for LQ air shipments, as they were under ORM-D-AIR
- Note the new, more restrictive LQ quantity limitations found in Table 3 of the newly revised 49 CFR §173.27
- Other significant changes include a drop test, secondary means of closure, & pressure differential testing
- The words “limited quantity” or “LTD QTY” are no longer required on the package itself or the Shipper’s Declaration for Dangerous Goods.
OCEAN SHIPPING DETAILS:
See Chapter 3.4 of IMDG Code book and Section 14 Transportation Section of Custom-Pak’s MSDS for your company’s product. Note that same LQ package markings can be used for ocean and ground shipments.
All hazmat employees need to be trained on these new requirements and your company’s training & shipping materials & records should be updated accordingly.
DISCLAIMER: While every attempt has been made to ensure the accuracy of this shipping information, Custom-Pak Products, Inc. makes no warranties or accepts any liability for any damages in connection with the re-shipping of any products manufactured by Custom-Pak Products, Inc. or others. We encourage you to have this information verified by appropriate internal or external personnel responsible for shipping regulations and associated training requirements.