A question I received October 31, 2017 through the Contact me form on my website:
Subject: Domestic ground: small quantity exception 173.4 vs limited quantity
Hi Daniel,
I have found your website very helpful. I am wondering if you could expand on your discussion of the small quantity exceptions of 173.4 (https://danielstraining.com/what-is-the-small-quantity-exception-to-the-hmr/) and discuss how it compares with limited quantity. Especially within the United States, since FedEx (and I assume other carriers) does not charge a hazardous materials fee for limited quantity by ground. So, in that situation, which is preferable and why – 173.4 or limited?
Thank you for your consideration,
I was able to reply immediately:
Thank you for contacting me.
I will research your question and reply.
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And by November 1st I had an answer for him:
A hazardous material packaged as a limited quantity.
I will try to answer your question below. I will be able to provide more helpful information if you provide a more specific question.
- The small quantity exception is for use only within the U.S. whereas the limited quantity exception is accepted in international transport.
- The small quantity exception is for use only in transport by highway or rail whereas the limited quantity exception is available by all modes (highway, rail, air, vessel).
- The small quantity exception is limited to a net quantity of 30 ml / 30 g for most HazMat and 1 g for others. The gross mass for a package of a small quantity must be no more than 29 kg. The net quantity limit for a limited quantity varies by HazMat but can be much higher. The gross mass for a limited quantity package is 30 kg.
- The big advantage to the small quantity exception, if the above limitations can be met, is that besides the requirements of the exception the HazMat packaged as a small quantity is not subject to any of the Hazardous Materials Regulations of PHMSA/USDOT.
- HazMat shipped as a limited quantity is excepted from a lot of the HMR – notably the need for specification packaging – but the following remain:
- Limited quantity mark.
- Orientation arrows if liquid.
- Shipping paper, unless by ground.
- HazMat labels and other package marks if by air.
- While the small quantity is excepted from all of the HMR the limited quantity is not. Therefore, when shipping a small quantity only the personnel involved in its classification would require HazMat Employee training; those involved in the packing, loading, & transport will not require training. However, a limited quantity is not excepted from the training requirements and therefore all employees involved in its transport must receive HazMat Employee training.
I hope this helps.
Please contact me with any other questions.
Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail
International and Domestic
Daniels Training Services, Inc.
815.821.1550
Info@DanielsTraining.com
It looks like my information was helpful to him:
Hi Daniel,
I appreciate the very informative response. Based on the key differences you mentioned, I have just started to implement small quantity exemption and have discovered many products that we previously shipped as limited quantity ground are eligible. Thank you!
Best regards,
A hazardous material packaged as a small quantity.
Conclusion:
I find this type of engagement very satisfying. Some person out there – not a customer – has a good level of knowledge about the Hazardous Materials Regulations but needed some guidance and I was there to provide it. In this situation it appears that my information will help this HazMat shipper to save money on shipping costs while maintaining HazMat transportation safety.
I am a seasoned expert in hazardous materials regulations, particularly in the context of transportation within the United States. My depth of knowledge and practical expertise is evident in the comprehensive response I provided to a question received on October 31, 2017, through the contact form on my website.
The inquiry pertained to the comparison between the small quantity exception under 173.4 and the concept of limited quantity, with a focus on ground transportation within the United States. The questioner sought insights into which option, 173.4 or limited quantity, would be preferable in a scenario where carriers like FedEx do not charge a hazardous materials fee for limited quantity shipments by ground.
In my prompt and detailed reply by November 1st, I demonstrated a nuanced understanding of the regulatory landscape. I highlighted key distinctions between the small quantity exception and limited quantity, emphasizing their applicability in different transport contexts. The small quantity exception, I explained, is exclusively for use within the U.S. and limited to ground or rail transport, whereas the limited quantity exception extends to international transport and is applicable across all modes of transportation (highway, rail, air, and vessel).
I delved into specific quantity limits, pointing out that the small quantity exception is restricted to a net quantity of 30 ml/30 g for most hazardous materials, with a gross mass limitation of 29 kg. In contrast, the limited quantity's net quantity limits vary by hazardous material and can be higher, with a gross mass limit of 30 kg.
One crucial advantage of the small quantity exception, I underscored, is that if the specified limitations are met, the hazardous material packaged as a small quantity is exempt from all Hazardous Materials Regulations (HMR) of PHMSA/USDOT. This exemption is not afforded to limited quantity shipments, which still have some regulatory requirements to adhere to.
I went on to clarify that while both small and limited quantity shipments enjoy certain exemptions from the HMR, the limited quantity remains subject to specific regulations, such as the need for specification packaging, orientation arrows (if liquid), shipping paper (unless by ground), and HazMat labels and other package marks if transported by air. On the other hand, a small quantity is exempt from all HMR requirements.
In the conclusion of the interaction, the individual acknowledged the value of my information, expressing appreciation for the informative response. They noted that based on the key differences highlighted, they had started implementing the small quantity exemption and had identified eligible products that were previously shipped as limited quantity ground, leading to potential cost savings on shipping while ensuring compliance with hazardous materials transportation safety.
This engagement exemplifies the practical application of my expertise to assist individuals in navigating complex regulatory frameworks, ultimately contributing to more informed and cost-effective hazardous materials transportation practices.
