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"
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?
- Placarding of trucks is not required.
- A signed shippers certification is not
required for GROUND shipments
- UN approved packaging is not required.
Do Consumer Commodity
Shipments require Hazard Labels?
Yes and no.
Internationally they require a Class 9 Miscellaneous Hazard
Domestically they require a rectangular ORM-D Marking
or "ORM-D Air" for shipments by UPS Air or USPS.
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:
Function Oriented Training
General Awareness 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
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 cant go as ORM-D or Class 9.
Whats the difference
between IATA Class 9 Consumer Commodity and DOT "ORM-D"
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 dont
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.