Shipping Limited Quantities, Excepted Quantities,
and ORM-D Consumer Commodities



You May be Shipping Hazmat and Not Even Know it.

Many businesses are surprised to find out that commonly shipped products are often classified as hazmat under the U.S. Department of Transportation's Hazardous Materials Regulations. The same is true for reverse logistics operations, including recalls and product returns. Everyday items like cleaning products, compressed air dusters, adhesives, paints and cosmetics are just a few of the products that may be considered hazardous materials.

Even if you only ship small quantities... the rules still apply! Don't find out that you are shipping hazmat from a DOT inspector. Labelmaster can help you avoid fines and stay compliant.

     

Do you need DOT labels? Search Label Finder now!


What really are Dangerous Goods?

What is Dangerous Goods? Did you ship any items classified as Dangerous Goods today? The generally accepted definition of Dangerous Goods (or hazardous materials) from the U.S. DOT is: "Any substance which may pose an unreasonable risk to health and safety of operating or emergency personnel, the public, and/or the environment if not properly controlled during handling, storage, manufacture, processing, packaging, use, disposal, or transportation."

This dangerous goods infographic takes a look at items you may be surprised to learn are Dangerous Goods.



Shipping Examples

The following information is intended to provide information for shipping hazardous materials using several exceptions in the domestic and international regulations. Each example includes diagrams of package marking and labeling, applicable documentation requirements and regulatory texts that applies to each scenario. Consult mode-specific regulations for complete regulatory reference.

For more information on shipping excepted quantities, limited quantities, ORM-D, and other exceptions, contact 1-800-621-5808.

Shipping Dangerous Goods in Excepted Quantities
Excepted Quantity Labels
Shipping Limited Quantities
Limited Quantity Labels
Consumer Comodities
ORM-D Labels


Shipping by Ground Within the U.S.


Excepted Quantities

Materials other than articles in the following Classes/Divisions that are authorized for transport aboard passenger aircraft under the 49 CFR regulations and meeting the criteria below may be transported as
Excepted Quantities (Class 7 not covered):

  • Division 2.2 gases with no subsidiary hazard (except aerosols)
  • Class 3
  • Class 4 PG II and PG III materials (except for self reactives)
  • Division 5.1 PG II and PG III materials
  • Division 5.2 only when contained in a chemical or first aid kit
  • Division 6.1 other than a PG I, Hazard Zone A or B material
  • Class 8 PG II and PG III materials (except UN2803, Gallium and UN2809, Mercury)
  • Class 9 (except UN1845, Carbon Dioxide Solid or Dry Ice and all lithium cells/batteries)

Package must be marked with the Excepted Quantities mark with the following information added:

The "*" must be replaced by the primary hazard class,
or when assigned, the division of each of the hazardous materials contained in the package.

The "**" must be replaced by the name of the shipper
or consignee if not shown elsewhere on the package.

Your shipment requires a Straight Bill of Lading Form with appropriate regulatory Basic Description.



Limited Quantities

Materials that are authorized specifically listed in the Packaging Exceptions column (8A) of the Hazardous Materials Table, and further authorized in the appropriate "Exceptions" subsection, may be transported under the Limited Quantities provisions (Class 7 not covered):

  • Certain shipments of "Cartridges, Small Arms" and "Cartridges, Power Device"
  • Certain Division 2.1 and 2.2 gases (2.3 non-pressurized gas samples may also qualify)
  • Certain Class 3 materials
  • Certain Division 4.1 PG II and III materials
  • Certain Division 4.2 PG III materials
  • Certain Division 4.3 PG II and III materials
  • Certain Division 5.1 PG II and III materials
  • Certain Division 5.2 materials that do not require temperature control
  • Certain Division 6.1 PG II and III materials (Toxic by inhalation materials do not qualify)
  • Certain Class 8 PG II and III materials
  • Certain Class 9 PG II and III materials
Shipping Limited Quantities
Limited Quantity Labels
Straight Bill of Lading Form
Straight Bill of Lading Form

Consult the 49 CFR to ensure proper documentation for your shipment.


ORM-D Consumer Commodities

The 49 CFR §171.8 defines consumer commodity as: "Material that is packaged and distributed in a form intended or suitable for sale through retail sales agencies or instrumentalities for consumption by individuals for purposes of personal care or household use. This term also includes medicines and drugs."

The 49 CFR further elaborates in §173.144 that (excerpt): "ORM-D material" means a material such as a consumer commodity, cartridges, small arms, or cartridges, power devices which, although otherwise subject to the regulations of this subchapter, presents a limited hazard during transportation due to its form, quantity and packaging. The article or substance must be a material for which exceptions are provided in Column (8A) of the §172.101 Hazardous Materials Table.

Only authorized packages of limited quantities that contain a material that meets the definition of a "consumer commodity" may be renamed "Consumer Commodity" and reclassed as ORM-D.

Here are some general guidelines as to what materials may qualify as limited quantities (excluding hazardous substances and hazardous wastes) which could then potentially be reclassed as ORM-D (Class 7 not covered):

  • Certain shipments of "Cartridges, Small Arms" and "Cartridges, Power Device"
  • Certain Division 2.1 and 2.2 gases (certain 2.3 non-pressurized gas samples may also qualify)
  • Certain Class 3 materials
  • Certain Division 4.1, PG II and PG III materials
  • Certain Division 4.2, PG III materials
  • Certain Division 4.3, PG II and III materials
  • Certain Division 5.1, PG II and III materials
  • Certain Division 5.2 materials that do not require temperature control
  • Certain Division 6.1 PG II and III materials (Toxic by Inhalation materials do not qualify)
  • Certain Class 8, PG II and III materials
  • Certain Class 9, PG II and III materials

For more information, you can review the 16 CFR, §503.5 - Interpretation of the definition of "consumer commodity" as contained in section 10(a) of the Fair Packaging and Labeling Act.


ORM-D Consumer Commodity Labels
ORM-D Labels
Straight Bill of Lading Forms
Straight Bill of Lading Form

Examples of ORM-D Markings compliant with 49 CFR 173.150 through 173.155 and 173.306 and 173.63.


Shipping by Air To, From, Within, or Outside the U.S.


Excepted Quantities

Materials in the following Classes/Divisions that are authorized for transport aboard passenger aircraft under the international air regulations (Dangerous Goods List) and US State Variations, as applicable, and meeting the criteria below may be transported as Excepted Quantities (Class 7 not covered):

  • Division 2.2 gases with no subsidiary hazard except UN1044, UN1950, UN2037, UN2073, UN2857, and UN3164
  • Class 3 material except PG I materials with a subsidiary hazard and UN1204, UN2059, UN3064, UN3256, UN3269 (unless authorized under SP A163), UN3357, UN3379, and UN3474
  • Division 4.1 PG II and PG III materials except UN2304, UN2448, UN2555, UN2556, UN2557, UN2907, UN3176, UN3221 through UN3240, UN3319 and UN3344
  • Division 4.2 PG II and PG III materials
  • Division 4.3 PG II and PG III materials except for UN3292 and UN3476
  • Division 5.1 PG II and PG III materials except for UN3356 and UN2426
  • Division 6.1 materials except for those having an inhalation toxicity of PG I and UN1600, UN1700, UN2016, UN2017, UN2312 and UN3250
  • Class 8 PG II and PG III materials except UN1774, UN2028, UN2215 (Molten), UN2576, UN2794, UN2795, UN2800, UN2803, UN2809, UN3028, UN3477 and UN3506
  • Class 9 materials except UN1845, UN2807, UN2990, UN3072, UN3090, UN3091, UN3166, UN3171, UN3245, UN3257, UN3258, UN3268, UN3316 (unless authorized under special provision A163), UN3363, UN3480, and UN3481

Use Label Finder's Shipping Name Finder to find the proper shipping name label for each UN dangerous good.



Package must be marked with the Excepted Quantities mark with the following information added:

The "*" must be replaced by the primary hazard class, or when assigned, the division of each of the hazardous materials contained in the package.

The "**" must be replaced by the name of the shipper or consignee if not shown elsewhere on the package.



A shipping paper is not required, but, if a document such as an air waybill accompanies a shipment, the document must include the statement "Dangerous Goods in Excepted Quantities" and indicate the number of packages. Example statement: "Cosmetics, Dangerous Goods in Excepted Quantities, 1 pkg"


Limited Quantities

Materials which are permitted on passenger aircraft and which meet the criteria of the following classes, divisions and packing groups (as appropriate) and are specifically listed in the Dangerous Goods List as being authorized may be carried under the limited quantities provisions.

  • Division 2.1 UN1950 and UN2037 materials that have no subsidary risk, and UN3478
    and UN3479 cartridges
  • Division 2.2 UN1950 and UN2037 materials that have no subsidiary risk
  • Class 3 PG II and III materials
  • Division 4.1 PG II and III materials, excluding self-reactive substances
  • Division 4.3 PG II and PG III, solid materials only
  • Division 5.1 PG II and PG III materials
  • Division 5.2 when contained in a chemical or first-aid kit
  • Division 6.1 PG II and III materials
  • Class 8 PG II and PG III materials except UN2794, UN2795, UN2803, UN2809, UN3028
    and UN3506
  • Class 9 authorized materials: UN1941, UN1990, UN2071, UN3077, UN3082, UN3316,
    UN3334, UN3335, and ID8000

Use Label Finder's Shipping Name Finder to find the proper shipping name label for each UN dangerous good.



Arrow Orientation Labels
Arrow Orientation Labels
DOT Hazard Class Labels
Hazard Class Labels
Limited Quantity Labels
Limited Quantity Labels
Shipper's Declaration for Dangerous Goods Forms
Shipper's Declaration for Dangerous Goods Forms



Shipping by Ocean To, From, Within, or Outside the U.S.


Excepted Quantities

Dangerous Goods that are authorized for transport aboard vessels that are listed in the IMDG Code Dangerous Goods List and US regulations, as applicable, may be transported as Excepted Quantities (Class 7 not covered).



Package must be marked with the Excepted Quantities mark with the following information added:

The "*" must be replaced by the primary hazard class, or when assigned, the division of each of the hazardous materials contained in the package.

The "**" must be replaced by the name of the shipper or consignee if not shown elsewhere on the package.

Your shipment requires a IMO Dangerous Goods Declaration with appropriate regulatory Shipping Marks.




Limited Quantities

Dangerous Goods that are authorized for transport aboard vessels that are listed in the IMDG Code Dangerous Goods List and US regulations, as applicable, may be transported as Limited Quantities.

Arrow Orientation Labels
Arrow Orientation Labels
Shipping Limited Quantities
Limited Quantity Labels
Get your Shipper's Declaration for Dangerous Goods forms at Labelmaster.




It is the shippers' responsibility to determine the suitability of all packaging, forms, labels, including any requirement for absorbent material, in accordance with modal requirements for use with contents.


PLEASE CONSULT ALL APPLICABLE REGULATIONS.