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. This situation creates a number of confusions, especially as laws and regulations change over time.
Many common consumer items will need to have a designation of ORM-D for shipping. ORM-D is a label that identifies other certain potentially hazardous materials for domestic transport only (though have limited risk during transportation because of their quantity and packaging). These items are regulated by the Department of Transportation and have special requirements regarding shipping and handling.
Items that need to be identified with ORM-D include (but are not limited to):
These items can be shipped in limited quantities and require proper labeling. If shipping Ground, they do not require additional paperwork (though you should inform any logistics partners; see below.)
A few years ago, regulations changed to phase out the ORM-D designation. Those regulations also changed the designation “Consumer Quantity” to “Limited Quantity.” Both labels mean the same thing, but updated documents will refer to Limited Quantity.
All such products must be appropriately marked. Effective 2014, 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.
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 pro-active about helping sellers with ORM-D materials, however. Amazon.com, for example, claims that it’s 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 is responsible for determining when something needs to be labeled ORM-D. 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 requirements is not complicated, but failing to do so can lead to excess hazmat fees, or worse, hefty fines.
Bill Young – Senior Vice President / Business Development
Materialogic has experience storing and shipping many consumer products that fall under the older ORM-D and newer Limited Quantity designations. If you have any questions or would like to discuss ways to simplify this aspect of your business, contact us.