ICC's Regulatory Helpdesk
Regulatory Helpdesk: April 23

Using absorbents with variation packaging, UN marking height, limited quantity, and de minimis quantities

Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. We’re here to help you become independent with – and understand the whys and hows – of the regulations.

Absorbent Materials in Variation Packaging

Q. Can I use absorbent padding instead of the vermiculite as the absorbent in a 4GV package that was tested with vermiculite?
A. Per the 49 CFR §178.601, the packaging must meet the standard to which it is certified and the material must be of the same type or design as used in the tested design type, in this case vermiculite. Therefore vermiculite would have to be used to comply with the regulations.

UN Number Height

Q. Is there a minimum size requirement for the UN number on a lithium battery mark?
A. The only place that a specific size requirement is referenced regarding the UN number on a lithium battery mark is in the IATA DGR – §7.1.5.5.2(b)- which states that the UN number “should be” at least 12 mm high.

None of the other common (49 CFR §173.185(c)(3)(i); IMDG §5.2.1.10; TDG §4.24; or UN Model §5.2.1.9) regulations quote a minimum UN number size specifically for the lithium battery mark. All of the regulations referenced allow for proportional reduction, of features without specified dimensions, when the authorized option for a reduced lithium battery mark is applied.

So, if the UN number is legible and meets the general minimum size (based on package size), specified in all but TDGR, then a reduction should be allowed for all.

[If the IATA DGR are amended to change “should be” to “must be”, then as a feature with specified dimensions, the UN number size of at least 12 mm would have to be maintained. However, even if the starting size of the UN number is 12 mm and if proportional reduction is subsequently permitted, then 7 mm would be adequate based on the general 59.9% reduction allowed in the mark for smaller packages. Note that all but the TDGR do have general UN number size requirements on packages, based on the package size.]

Limited Quantity (49 CFR)

Q. Can a corrosive liquid in packing group III be shipped as limited quantity? I’m in §173.154 which is where the HMT directed me.  Is the limit per package or per inner container?
A. Per §173.154, for a PG III material the inner packaging of a combination packaging cannot be more than 5 liters or 1.3 gallons. This means you can have two (2) inners each one 2.5 liters in size or one inner that is up to 5 liters in size.

De Minimis (49 CFR)

Q. Can I use the de minimis exception in 49 CFR for a material that is non-hazardous?
A. If the transport classification of the material is truly not hazardous, then no parts of the 49 CFR Hazardous Materials Regulations apply. There is no need to use the 49 CFR in this instance. However, if your material is in fact hazardous and in inner containers that are 1 ml (0.03 ounces for a liquid or 1 gram (0.04 ounces for a solid), then this particular exception could be used.

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