AFTER ORM-D: SHIPPING HAZMAT
CONSUMER COMMODITIES IN 2021
Executive Summary
As of January 1, 2021, the ORM-D designation for hazardous materials consumer commodities is no more. This guide covers key requirements you
must know to ship hazmat consumer commodities by ground, air, and vessel—in 2021 and beyond.
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How to Ship Hazmat Consumer Commodities in 2021
What is a consumer commodity?
US DOT’s Hazardous Materials Regulations (HMR) define a consumer
commodity as “a material that is packaged and distributed in a form intended
for, or suitable for, retail sale for consumption by individuals for personal care
or household use. This term also includes drugs and medicines.”
[49 CFR 171.8]
Examples of hazardous material consumer commodities include many
everyday consumer products.
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How to Ship Hazmat Consumer Commodities in 2021
Corrosive drain
de-clogging
Hand sanitizer Essential oils Mouthwash Paint thinner liquids
Waterproof Cleaning
Ink Paint Medicines mascara compounds
Hairspray and Adhesives
other aerosol Lighters and containing
products matches Stains flammable liquids Pesticide sprays
Nail polish
Isopropyl
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alcohol remover Perfume Varnishes Bleach
How to Ship Hazmat Consumer Commodities in 2021
As of January 1, 2021, ORM-D is O-V-E-R
Until December 31, 2020, US DOT allowed shippers to re-class some
hazardous material consumer commodities as Other Regulated
Materials-D (ORM-D) and re-name them “consumer commodity.”
The ORM-D designation afforded exceptions from many packaging,
marking, and labeling regulations, as well as the requirement for DOT
shipping papers.
As of January 1, 2021, the ORM-D classification is no longer allowed
in ground transportation.
In order to qualify for relief, hazmat consumer commodities now must
be shipped according to the regulations for limited quantities.
Here’s the good news: Limited quantity shipments are typically
afforded the same exceptions as ORM-D shipments when you follow
some basic requirements.
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How to Ship Hazmat Consumer Commodities in 2021
Shipping Hazmat Consumer Commodities
By Ground
When shipped by ground, limited quantity hazmat packages are afforded most of the
same reliefs that ORM-D packages were before 2021.
Limited quantity hazmat packages are typically excepted from:
• Hazard class labeling;
• Use of specification packaging;
• Shipping paper and emergency response information; and
• Placarding vehicles.
Remember: A limited quantity of hazmat is still hazmat. You must comply with certain
requirements to ensure safe transportation by ground.
Limited quantity packages must:
• Not exceed a gross weight of 30 kg (66 lbs.);
• Meet general packaging requirements in 49 CFR 173, Subpart B; and
• Be packed in “combination” packaging (e.g., bottles or cans in a box).
DOT typically limits inner packagings to 1 to 5 kg capacity, depending on the hazard
class and packing group of the material.
The Shipping Limited Quantities & Consumer Commodities For ground transportation, hazmat consumer
online course covers the latest requirements for shipping commodity shipments must be marked with the
small quantities of hazardous materials by ground (49 CFR), limited quantity marking shown here.
air (IATA DGR), and vessel (IMDG Code).
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How to Ship Hazmat Consumer Commodities in 2021
Shipping Hazmat Consumer Commodities
By Air
The International Air Transport Association’s Dangerous Goods Regulations (IATA
DGR) lays out additional rules for shipping consumer commodities by air.
The Proper Shipping Name (PSN) “consumer commodity” with ID number 8000
exists in the IATA DGR and is regulated as a miscellaneous Class 9 dangerous good.
Very few materials can be shipped by air using the consumer commodity
regulations. For a list of approved materials, Special Provision A112 in Column M of
the IATA DGR 4.2 List of Dangerous Goods sends the shipper to IATA DGR 4.4.
Only these hazard classes and packing groups may be shipped as consumer
commodities by air:
• Class 2, non-toxic aerosols
• Class 3, PG II and III only
• Division 6.1, PG III only
• UN 3077, Environmentally hazardous substance, solid, n.o.s.
• UN 3082, Environmentally hazardous substance, liquid, n.o.s.
• UN 3175, Solids containing flammable liquid, n.o.s.
• UN 3334, Aviation regulated liquid, n.o.s.
• UN 3335, Aviation regulated solid, n.o.s.
The Hazmat Air Shipper Certification online course builds on your
49 CFR expertise to cover the latest international standards for air
shipments. Learn all the additional requirements you must know to
ship hazardous materials by cargo or passenger aircraft.
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How to Ship Hazmat Consumer Commodities in 2021
Shipping Hazmat Consumer Commodities
By Air
Using Packing Instruction Y963
The IATA DGR Packing Instruction used to ship consumer commodities by air is Y963, found in
IATA DGR Section 5.9.
PI Y963 is where you will find requirements and reliefs that apply to your material, like:
• Packaging requirements (e.g., combination packaging must be used);
• Reliefs (e.g. UN-rated packaging not required); and
• Quantity limits for inner packagings.
TWO NOTES
1. Orientation arrows are required only for
packages that contain liquids.
2. When you offer multiple packages that
differ in gross weight, you must mark the
gross weight of each package (e.g., “5 kg G”
and “3 kg G”) adjacent to the Proper Shipping
Name and UN number.
A consumer commodity packaged, marked, and
labeled for air transportation will look something
like the box shown here.
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How to Ship Hazmat Consumer Commodities in 2021
Shipping Hazmat Consumer Commodities
By Air
When ID 8000 Won’t Fly
What if you want to ship a material that is packaged as a consumer commodity, but is not one of the hazard classes,
divisions, or packing groups authorized by Special Provisions A112?
One option: Ship it as a limited quantity.
For example, “Hypochlorite solution” is a Class 8 dangerous good—a hazard class that is not authorized to be shipped
using the name “Consumer Commodity.” However, if the package does not exceed 0.5 L for a PG II, or 1 L for a PG III, it is
authorized to be shipped as a limited quantity using Packing Instruction Y840 or Y841, respectively.
The principal differences between this limited quantity package and a consumer commodity package are as follows:
• The Proper Shipping Name will be “Hypochlorite Solution” instead of “Consumer Commodity”
• The UN Identification number UN 1791 will be used rather than ID 8000
• Instead of a Class 9 hazard label, the package will be labeled with a Class 8 corrosive label.
So, the package will look like this:
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How to Ship Hazmat Consumer Commodities in 2021
Shipping Hazmat Consumer Commodities
By Vessel
For vessel transport, a shipment packaged as a consumer commodity can be shipped fully
regulated or, more commonly, as a limited quantity.
The IMDG Code does not have a special category like the DOT’s old ORM-D. Nor does
it allow shippers to use the Proper Shipping Name “Consumer Commodity” under
miscellaneous Class 9 like IATA does.
When shipped by vessel, materials retain their original Proper Shipping Names and hazard
classes for shipping paper entries.
If the inner packaging quantities are within the limits expressed in Column (7a) of the
IMDG 3.2 Dangerous Goods List and the package meets all the requirements of IMDG
Chapter 3.4, then the consumer commodity can be shipped as a limited quantity. In that
case, the package (containing liquids) may look like this:
Like limited quantity ground shipments, an eligible
consumer commodity shipped by vessel needs only
the limited quantity marking.
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How to Ship Hazmat Consumer Commodities in 2021
Shipping Hazmat Consumer Commodities
By Ground, Air, and Vessel
The table below is a quick reference guide to help you prepare consumer commodity
basic description entries for shipping papers by mode of transportation.
Regulation Basic Description Entry Comment
49 CFR N/A In general, limited quantities are excepted from
Ground (Highway the shipping paper requirements of Part 172,
and Rail) Subpart C
IATA DGR a. Authorized a. Only those materials authorized by Special
ID 8000, Consumer Commodity, 9 Provision A112 at IATA DGR 4.4 (from column M of
(Note: No packing group) IATA DGR 3.2 List of Dangerous Goods)
b. Unauthorized as consumer commodity b. Ship as limited quantity or fully regulated
UN #, PSN, hazard class (subsidiary when
applicable), PG II or III
Example: UN 1791, Hypochlorite Solution, (Note: The words “limited quantity” or “Ltd. Qty.”
8, PG II are not indicated after the basic description. The “Y”
packing instruction fulfills this communication.)
IMDG Code UN #, PSN, hazard class (subsidiary when Limited quantities retain their original Proper
applicable), PG II or III Limited Quantity or Shipping Name (PSN) and hazard class
Ltd. Qty.
Example: UN 1791, Hypochlorite Solution, (Note: Excluded from the words “marine
8, PG II Limited Quantity pollutant” per IMDG 2.10.2.7)
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How to Ship Hazmat Consumer Commodities in 2021
Building Confident Compliance Teams
Effective training is the key to a confident and productive workforce. To help you and your team
build a strong compliance program and understand the regulations that affect your business,
Lion Technology designs training to empower as well as educate. Since 1977, two out of three
Fortune 500 companies in manufacturing, chemical, and transportation industries—as well
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If you’re responsible for compliance with RCRA hazardous waste rules; 49 CFR, IATA, or IMO
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