{"id":18069,"date":"2022-06-16T07:23:14","date_gmt":"2022-06-16T07:23:14","guid":{"rendered":"http:\/\/shipip.com\/?p=18069"},"modified":"2022-06-16T07:23:14","modified_gmt":"2022-06-16T07:23:14","slug":"can-i-use-the-orm-d-and-limited-quantity-markings-together","status":"publish","type":"post","link":"https:\/\/developmenttask.com\/ShipIpLtd\/can-i-use-the-orm-d-and-limited-quantity-markings-together\/","title":{"rendered":"CAN I USE THE ORM-D AND LIMITED QUANTITY MARKINGS TOGETHER?"},"content":{"rendered":"
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Although the Other Regulated Material-Domestic (ORM-D) designation was phased out on January 1, 2021 for highway shipments, many shippers have questions about how to move forward. PHMSA recently responded to one question: Is a shipper required to remove or cover the ORM-D marking entirely, or can it appear in addition to the required limited quantity marking?<\/p>\n

The\u00a0Hazardous Materials Regulations<\/i>\u00a0(HMR<\/i>) require limited quantity packages prepared for highway transportation to be marked with the limited quantity marking. There is\u00a0no explicit requirement<\/a>\u00a0for the outdated ORM-D marking to be removed.<\/p>\n

In an interpretation dated May 18, 2022, PHMSA warns that although the ORM-D marking may remain on a package when the correct limited quantity marking is used for ground shipping,\u00a0this can be confusing and potentially problematic.<\/b><\/p>\n

If both markings appear, the package may be rejected or removed from transportation since hazardous materials are no longer permitted to be reclassed as ORM-D. Not every shipper, carrier, or freight forwarder will see this letter of interpretation. Those that do not may be unsure about accepting or loading a package with both ORM-D and limited quantity markings.<\/p>\n

Since the packages display the currently required limited quantity marking, the old ORM-D marking is not required to be removed prior to shipment. However, it is the opinion of this Office that the display of the ORM-D marking is confusing and may frustrate transportation of these packages because hazardous materials are no longer authorized to be reclassed as ORM-D for transport. Therefore, while not covering the phased-out ORM-D marking is not in violation of the HMR, we suggest that the best way to avoid frustration of the shipment is to cover the ORM-D marking and to discontinue its use in future shipments.<\/p>\n

PHMSA Reference No. 22-0019<\/a><\/p><\/blockquote>\n

To help address this issue, PHMSA is working on a rulemaking to remove all references to ORM-D in the 49 CFR 172.101 Hazardous Materials Table.\u00a0An FAQ page<\/a>\u00a0on PHMSA\u2019s website to convert letters of interpretation like this one into an easy-to-read, public format is also under consideration. A public webinar is scheduled for June 27, 2022 to discuss the FAQ page and will accept comments until July 22, 2022.<\/p>\n

What Happened to ORM-D?<\/b><\/h3>\n

The last day to use the ORM-D classification for highway shipments was December 31, 2020.<\/p>\n

Shippers who used the ORM-D designation to ship small quantities of hazardous materials packaged for retail sale benefited from a multitude of reliefs. Now that ORM-D has been phased out, the same materials, in the same quantities, in the same packaging, mostly continue to qualify for relief\u00a0under US DOT\u2019s limited quantity regulations<\/a>.<\/p>\n

What changed was the label you affix to your packages. Ground shipments of limited quantities must carry the blank limited quantity mark. Limited quantity air shipments must display a \u201cY\u201d limited quantity marking.<\/p>\n

Want More on Limited Quantities?<\/b><\/h3>\n

Be confident you know how to package, mark, and label your limited quantity shipments now that ORM-D is O.V.E.R.<\/p>\n

The\u00a0Shipping Limited Quantities and Consumer Commodities<\/a>\u00a0online course provides reliable, up-to-date training to help satisfy DOT, IATA, and IMDG training mandates for hazmat employees who prepare or offer limited quantity shipments for ground, air, or vessel transport.<\/p>\n<\/div>\n<\/div>\n<\/div>\n

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Although the Other Regulated Material-Domestic (ORM-D) designation was phased out on January 1, 2021 for highway shipments, many shippers have questions about how to move forward. PHMSA recently responded to one question: Is a shipper required to remove or cover the ORM-D marking entirely, or can it appear in addition to the required limited quantity […]<\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[135],"tags":[136],"class_list":["post-18069","post","type-post","status-publish","format-standard","hentry","category-inventory-of-hazardous-materials-ihm","tag-inventory-of-hazardous-materials-ihm"],"_links":{"self":[{"href":"https:\/\/developmenttask.com\/ShipIpLtd\/wp-json\/wp\/v2\/posts\/18069","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/developmenttask.com\/ShipIpLtd\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/developmenttask.com\/ShipIpLtd\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/developmenttask.com\/ShipIpLtd\/wp-json\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/developmenttask.com\/ShipIpLtd\/wp-json\/wp\/v2\/comments?post=18069"}],"version-history":[{"count":0,"href":"https:\/\/developmenttask.com\/ShipIpLtd\/wp-json\/wp\/v2\/posts\/18069\/revisions"}],"wp:attachment":[{"href":"https:\/\/developmenttask.com\/ShipIpLtd\/wp-json\/wp\/v2\/media?parent=18069"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/developmenttask.com\/ShipIpLtd\/wp-json\/wp\/v2\/categories?post=18069"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/developmenttask.com\/ShipIpLtd\/wp-json\/wp\/v2\/tags?post=18069"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}