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U.S. Department of Transportation

Hazardous Materials Requirements for "Consumer Commodities"

Frequently Asked Questions about ORM-D and ID 8000 Consumer Commodities

 

 

What is a "Consumer Commodity"

It is a hazardous material that is packaged in a form intended or suitable for retail sale. Generally small packagings, the shipping name includes items such as Cosmetics, Paints, Aerosols, Medicines, Nail Polish, etc.

So, is a "Consumer Commodity" considered "hazmat" or "dangerous goods"

Yes. Absolutely. As a hazardous materials shipper, you are required to train your employees involved in shipping Consumer Commodity shipments by Ground every 3 years, by Air or Ocean every 2 years.

What does "ORM-D" Mean?

ORM-D is the name of the hazard class assigned to consumer commodities under the US DOT regulations. Internationally Consumer Commodities are Class 9.

What are the exceptions in the regulations for ORM-D materials?

  1. Placarding of trucks is not required.
  2. A signed shippers certification is not required for GROUND shipments
  3. UN approved packaging is not required.

Do Consumer Commodity Shipments require Hazard Labels?

Yes and no. Internationally they require a Class 9 Miscellaneous Hazard Label.

Domestically they require a rectangular ORM-D Marking or "ORM-D Air" for shipments by UPS Air or USPS.

Is there a "Consumer Commodity" Proper Shipping Name for Ocean Shipments?

No, not exactly. Under the IMDG Ocean regulations there is neither a hazard class nor a proper shipping name for Consumer Commodities, though there are certain exceptions from marking and labels these types of products as "Limited Quantities".

What type of training is required for Consumer Commodity Shippers?

Federal law requires these types of training:

ü Function Oriented Training

ü General Awareness Training

ü Safety Training

The degree of training that an employee requires is determined by his job responsibilities. A driver for example, may require "functional" training on loading and handling dangerous goods, cargo compatibility, shipping papers, and emergency response procedures, among others.

If ALL of your products qualify as Consumer Commodity and they are the ONLY hazardous items you ship, training could probably be done in one day. If only SOME of your products qualify as Consumer Commodity then you would need to receive training in the full regulations. You must understand how the items need to be shipped when they can’t go as ORM-D or Class 9.

What’s the difference between IATA Class 9 Consumer Commodity and DOT "ORM-D" Consumer Commodity?

ORM-D is the Domestic Classification for ground shipments. Class 9 is the classification by IATA for AIR shipments. Only UPS will accept ORM-D by air.

There are significant differences in the types and quantities of materials that are allowed to be reclassed as a Consumer Commodity. IATA is MUCH more restrictive than DOT, and there is a VAST difference in the quantities allowed. I.E. IATA only allows pint containers to be inner packagings of flammable liquids where DOT allows more than 1 gallon in some cases.

What happens if I don’t train my people to ship ORM-D or any hazmat?

You can be fined up to $27,500 per violation, per day. A typical fine for a medium size company is around $30,000 for an air violation.

 

 

 

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HazardousMaterials Requirements for Consumer Commodities FAQ



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