IMDG Limited Quantities Exceptions
Pipeline and Hazardous Materials Safety Administration · Oct 6, 1994 · Reference No. 96-0010
Interprets: 49 CFR § 171.12, 49 CFR § 172.203, 49 CFR § 172.301
This is in response to your letter concerning possible differences in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) and the International Maritime Dangerous Goods Code (IMDG) with regards to limited quantity requirements (labeling, marking, packaging, documentation, etc.). I apologize for the delay in responding and hope that it has not caused you any inconvenience.
The requirements for import/export shipments are contained in § 171.12. If all or part of the transportation is by vessel, packages (e.g., limited quantity) conforming to IMDG regulations are acceptable for transportation within the United States (U.S.). However, if the imported packages are emptied and refilled with hazardous materials for further transport in the U.S., the shipments are fully subject to the HMR. Accordingly, shipments of hazardous materials from the contiguous 48 States to U.S. territories may comply either with the HMR or the IMDG. Section 172.301(f)(1) of the HMR excepts packages which contain limited quantities from identification marking requirements. Also, the phrase "Limited Quantity is not a required package marking under the HMR. As specified in § 172.203(b), the description for a material offered for transportation must include the words "Limited Quantity" or Ltd Qty" following the basic description.
If we can be of further assistance, feel free to contact us.
A letter of interpretation applies the regulations to the facts the requester described. It isn’t a regulation and isn’t legal advice. The agency’s copy.