New Option for Shipments of Pallet Loads of Waste Limited Quantities and Consumer Commodities

The Deparment of Transportatoin (DOT) has published a new exception [49 CFR 173.12(h)] for waste shipments of consumer commodities and limited quantities that are shipped as pallet loads. This exception, effective February 22, 2016, indicates that shrink-wrapped or stretch-wrapped pallets containing packages of waste consumer commodities or limited quantities may be transported by motor vehicle or cargo vessel under the following conditions:

• The waste materials must be in their original undamaged packaging and marked with the “Consumer Commodity ORM-D” marking in conformance with 49 CFR 172.316 or an authorized limited quantity marking in conformance with 49 CFR 172.315, as appropriate. The word “waste” in association with the proper shipping name is not required on individual packages;
• Packages must be securely affixed to a pallet and shrink-wrapped or stretch-wrapped;
• The outside of the shrink-wrap or stretch-wrap must be marked on opposite sides with either “Waste, Consumer Commodity, ORM-D” or “Waste, Limited Quantity.”

DOT added this new exception to the regulations so that all hazardous materials shippers can now take advantage of what was previously Special Permit 11470. This change in the regulations is part of the DOT’s effort to incorporate commonly used, proven safe, special permits into the regulations to provide wider access to the regulatory flexibility allowed under the special permits.