Yesterday we discussed license, registration, and placarding exceptions concerning transporting class 9 hazardous materials (hazmat). If a hazmat is exempt from placarding, it is usually the case that other exemptions also apply. Today we will look at labeling and shipping papers exceptions for class 9 hazmat transported by motor carriers on highways.
Note: This article discusses limited quantity exceptions for class 9 miscellaneous hazmat. Limited quantity exceptions are also available for classes 3, 4, 8, and other regulated materials (ORMs) and divisions 5.1 and 6.1 hazmat. These exceptions are permitted only if the regulation (in the case of class 9 hazmat—49 CFR 173.155) is referenced for the specific hazmat in the Hazardous Materials Table at 49 CFR 172.101.
Limited quantities of class 9 materials in Packing Groups II and III are excepted from labeling requirements unless they are being transported by air. They are also excepted from specification packaging requirements found at 49 CFR 178 when they are packaged in certain combination packagings.
The package must be in compliance with the packaging requirements for preparing hazmat for transportation found at 49 CFR 173.21 to 173.41. In addition, the package may not exceed 66 pounds (lb) (30 kilograms (kg)) gross weight.
Class 9 hazmat in Packing Group II may be combined if the inner packagings for liquids are up to 0.3 gallons (gal) net capacity and up to 2.2 lb net capacity for solids.
Class 9 hazmat in Packing Group III may be combined if the inner packagings for liquids are up to 1.3 gal net capacity and up to 11 lb net capacity for solids.
To meet the exception, combination packagings for both packing groups must be packed in strong outer packagings.
Strong outer packaging provides protection against the unintentional release of its contents. It is a packaging that is sturdy, durable, and constructed so that it will retain its contents under normal conditions of transportation. A strong outer packaging must meet the general packaging requirements found in 49 CFR 173 but need not comply with the specification packaging requirements in 49 CFR 178.
Limited quantity shipments do not need shipping papers when transported by highway or rail.
There are no segregation requirements for class 9 hazmat that is shipped by highway or rail.
Examples from the Hazmat Table
The Hazardous Materials Table (HMT), found at 49 CFR 172.101, identifies over 3,000 of the most commonly transported hazmat listed alphabetically by proper shipping name. Being familiar with the HMT provides one of the basic ways for your employees to identify hazmat and be able to complete shipping papers, mark and label hazmat packages, select appropriate placarding, and comply with other hazmat transportation requirements.
Column 3 of the HMT identifies the hazard class or division of a particular hazard class or division. In this exercise, we’ll pick a few of the hazardous materials identified as class 9 and see if they are eligible for the class 9 limited quantity exception. Remember, the limited quantity exception for class 9 hazmat is only permitted for Packing Groups II and III and if 49 CFR 173.155 is referenced on the HMT under column 8A. Column 8A contains exceptions from some of the requirements of 49 CFR 173. A “None” in this column means no packaging exceptions are authorized, except as may be provided by special provisions in Column 7.
Aluminum (molten). This class 9 hazmat is in Packing Group III. However, since the word “None” is in column 8A, the limited quantity exception does not apply for this material.
Asbestos. This is a class 9 hazmat in Packing Group III. Column 8A has the number “155”, which indicates that it is eligible for the limited quantity exception at 49 CFR 173.155.
Sulfur. This is a class 9 hazmat in Packing Group III. Since the word “None” is in column 8A, the limited quantity exception does not apply for this material.
In tomorrow’s Advisor, we will continue our focus on the transportation of hazmat with a look at some key differences in regulations.