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The following post is an excerpt from our September 2015 Regulatory Corner, a new Heritage news bulletin we will be including in future e-newsletters. To subscribe to our newsletter (and never miss an upcoming Regulatory Corner) click here.
In the January 19, 2011 Federal Register, DOT announced the elimination and replacement of the ORM-D marking for small quantities of hazardous materials shipments. The ORM-D marking has been mostly replaced with Limited Quantity (LQ), which is a diamond-shaped marking with black tips on the top and bottom. ORM-D may still be used, but only for ground shipments, until the deadline of December 31, 2020 (see January 7, 2013 extension notice). Additionally, to take advantage of ORM-D provisions your material also has to meet the DOT definition of a consumer commodity. This definition will also be removed, and is not a requirement to use the newer LQ designation.
The usage of ORM-D/LQ has benefits which can include:
A full discussion of these requirements is outside the scope of this post, but the key steps are as follows, using UN1759 Corrosive Solids, NOS as an example:
As mentioned above, these are the key steps only, and many different situations may be applicable. For example, if you are shipping RCRA hazardous wastes or exceed a DOT Reportable Quantity (RQ) for a single package, in most cases you will only be able to take advantage of the no DOT specification package aspect of the Limited Quantity/ORM-D exception provisions. Please review the requirements for each particular situation and ship your hazardous materials with a focus on safety.
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