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Limited quantity exception
  • HMR exceptions exist for limited quantities, which are smaller amounts of hazardous materials in non-bulk combination packages.
  • Limited quantity packaging must meet the requirements for quantity, weight, packaging, marking, and documentation that correspond to the material’s class/division as listed in HMT Column 8A.

Limited quantities are smaller amounts of hazardous materials in non-bulk combination packages. A limited quantity exception can only be used for a hazardous material if Column 8A of the Hazardous Materials Table (HMT) references the specific section in Part 173 that contains the exception.

The sections in Part 173 that contain the limited quantity requirements for the different hazard classes and divisions are as follows, with examples:

  • 173.306 - Class 2 (gases)
  • 173.150 - Class 3 (flammable and combustible liquids)
  • 173.151 - Class 4 (flammable solids)
  • 173.152 - Class 5 (oxidizers and organic peroxides)
  • 173.153 - Division 6.1 (poisons)
  • 173.421 - Class 7 (radioactives)
  • 173.154 - Class 8 (corrosives)
  • 173.155 - Class 9 (miscellaneous) Although not identified as limited quantities, Class 1 has some similar exceptions listed in Section 173.63 for certain less hazardous explosive materials.

Packaging

Limited quantity packaging must conform to the specifications, quantity, and weight limits specified for each hazard class/division and packing group. These specifications are listed in the section in Part 173 (listed in Column 8A of the HMT) that is applicable to the material.

Except for Class 1 and 7, each combination package may not exceed 66 pounds (30 kg) gross weight. The size of inner packagings that are allowed to be used varies depending on the hazard/division and packing group of the material.

For example, Class 8 materials in Packing Group III must be in inner packagings not more than 1.3 gallons (5 L) for liquids or 11 pounds (5 kg) for solids. These inner packagings must be packed in a strong outer packaging.

Markings

A package containing a limited quantity of hazardous materials must be marked as follows:

  1. Non-air packages containing a limited quantity must display the square-on-point limited quantity marking. A non-air package displaying the limited quantity marking does not have to be marked with the proper shipping name or identification number unless the material is a hazardous substance or hazardous waste. (172.315)
  2. Packages meeting the requirements for air transport must display the square-on-point “Y” limited quantity marking. A package displaying the “Y” limited quantity marking must be marked with the proper shipping name and identification number when transported by air. Packages displaying the square-on-point “Y” limited quantity marking are authorized for transport by all modes of transportation. (172.315)

The width of the border forming the square-on-point marking must be at least 2 mm. Each side of the marking must be at least 100 mm.

If the size of the package requires a smaller marking, then each side of the marking may be reduced to no less than 50 mm. For cargo transport units transported by water, each side of the marking must have a minimum size of 250 mm. (172.315)

Labels

Labels are not required for most limited quantities of hazardous materials. However, labels are required for a limited quantity transported by aircraft and for poison-by-inhalation materials. (173.150 - 173.155)

Shipping papers

In most situations, shipping papers are not required for a limited quantity of hazardous material. However, shipping papers are required for a limited quantity of a hazardous material that is a hazardous substance, hazardous waste, or marine pollutant, or is offered/transported by air or water. When a shipping paper is required, the words “Limited Quantity” or the abbreviation “Ltd Qty” must follow the basic description for the hazardous material. (172.203)

Training

If an employer offers or transports limited quantities, their employees are performing functions subject to the Hazardous Materials Regulations (HMR) and must receive hazmat training. Before these hazmat employees perform any function, they must be trained, tested, and certified as required by the HMR. (172.704)

Exceptions

Listing an emergency response telephone number on the shipping papers is not required for limited quantities. (172.604(c))

Most limited quantities are excepted from the specification packaging, shipping papers, labeling, and placarding requirements. Examples of this can be found in 173.150 through 173.155.

The exceptions section in Part 173 (listed in Column 8A of the HMT) gives the exceptions allowed and the requirements that must be met to offer and transport each specific material as a limited quantity.