The word “hazmat” conjures images of people in radiation suits cleaning up a spill or driving trucks of dangerous chemicals. The truth is that laws regulating hazardous materials cover a much wider range of substances, especially when it comes to shipping. Many common household items must be shipped in compliance with these laws; anywhere from a package of batteries to shaving cream can be considered hazardous. This situation creates a number of confusions, especially as laws and regulations change over time.
So what do we label our hazardous shipments as? Prior to 2020, you may be familiar with the designation of ORM-D. However, as of 2021, the Department of Transportation (DOT) has sunsetted the ORM-D label and now uses the designation "Limited Quantity" for identifying potentially hazardous materials for domestic transport. So ORM-D vs Limited Quantity is less of a comparison and more of a swap in terminology. These items are regulated by the DOT and have special requirements regarding shipping and handling.
Items that need to be identified with Limited Quantity include (but are not limited to):
These items can be shipped in limited quantities (hence the label) and require proper labeling. If shipping Ground, they do not require additional paperwork, though you should inform any logistics partners of your hazardous parcels.
As regulations changed to phase out the ORM-D label, those regulations altered the designation “Consumer Quantity” to “Limited Quantity.” Both labels mean the same thing, but updated documents will refer to Limited Quantity.
All such products in the list above must be appropriately marked as Limited Quantity. The marking for Limited Quantities for ground transport is a 4” square on point (though it can be as small as 2” for smaller packages). A ‘Y’ is placed on labels meant for air transport. The marking must be applied on at least one side or one end of the outer packaging.
The marking must be legible, durable, and readily visible. No other markings or hazmat stickers are needed if shipping Ground.
Also, all limited quantities packaging must meet certain physical requirements. They must be capable of passing a 1.2 meter (4′ high) drop test and a 3-meter (10′) stacking test. Your total gross mass cannot exceed 30 kg.
Carriers like FedEx and UPS have very specific requirements when it comes to Limited Quantity; these might be more restrictive than what is required by law. If you are shipping such items, you should make sure that you are following the carrier's specific requirements or working with a 3PL that can help guide you through the process.
Not all logistics partners are proactive about helping sellers with Limited Quantity materials, however. Amazon.com, for example, claims that its system is “not designed to recognize Hazmat until items have been manually reviewed by our Product Compliance department.” In other words, it is you, the seller, not Amazon or other retail partners, who are responsible for determining when something needs to be labeled as a hazardous material. If those products are shipped without being properly declared and labeled, the shipper could be liable and could face a hefty fine.
If any of the items you sell or ship might require a Limited Quantity designation, you should check in with your 3PL and/or any carriers you intend to use. If your items do in fact require this designation, you will need to make sure that your packaging adheres to regulation and that you (or your 3PL) have the appropriate stickers. Complying with the DOTs hazmat requirements is not complicated, but failing to do so can lead to excess hazmat fees, or worse: hefty fines.
At Materialogic, we ensure that every shipment not only arrives on time but is transported safely. With over 40 years of experience, you can trust that we know a thing or two about handling hazardous materials. Most commonly, we store and ship batteries and aerosol items. If you'd like to have a trusted, experienced hazard shipping 3PL partner in your corner, reach out to our team today to discuss how we can help.