Effective August 6, 2012, the Postal Service™ will revise Mailing Standards of the United States Postal Service, Domestic Mail Manual (DMM®) 601.10.8 to incorporate revisions made in response to the Department of Transportation (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) changes to 49 Code of Federal Regulations. The Postal Service will also make corresponding revisions to Publication 52, Hazardous, Restricted, and Perishable Mail, chapters 3 and 7, and Appendices.
The comprehensive rulemaking by the PHMSA, published in the January 19, 2011, Federal Register notice (76 FR 3308–3389), provided amendments to the Hazardous Materials Regulations (HMR) that aligned general domestic standards with international standards, and incorporated changes to proper shipping names, hazard classes, packing groups, special provisions, packaging authorizations, and limited quantities for surface and air.
PHMSA expects that the alignment of the existing limited quantity provisions in the HMR with international standards and regulations will enhance safety by facilitating a single uniform system of transporting limited quantity material. Because of the inherent risk unique to air transportation, PHMSA believes that full harmonization with the International Civil Aviation Organization Technical Instructions (ICAO TI) is necessary with regard to the material authorized and guidelines for limited quantities (including consumer commodities) intended for transport by air. The ICAO TI also includes specific provisions for air transport of dangerous goods in the mail, which are much more restrictive than the general standards. No dangerous goods are allowed in international mail, with the exception of certain infectious substances and radioactive materials as noted in subchapter 130 of the Mailing Standards of the United States Postal Service, International Mail Manual. These materials may only be sent by authorized mailers for authorized purposes.
In its January 19, 2011, Federal Register notice, PHMSA signaled its intent to eventually eliminate the “Other Regulated Material-Domestic” (ORM-D) classification. Mailers should be aware that the Postal Service also expects to eventually eliminate its ORM-D category and markings in favor of a “limited quantity” categorization that aligns with the revised PHMSA regulations.
In its rulemaking, PHMSA provided a January 1, 2013, implementation date for the air transportation segment of this rulemaking. These changes will result in the elimination of the “consumer commodity” category for products in hazard classes 4, 5, and 8, as well as a portion of class 9. In the near future, the Postal Service expects to announce a corresponding rulemaking to coordinate with PHMSA in regard to the categorization and marking of these materials in the domestic mailstream. In the interim, the optional marking standards that are being provided as a part of this revision are expected to align with the PHMSA regulations that will become effective on January 1, 2013.
In response to the PHMSA’a new regulations, the Postal Service will provide mailers with the option of continuing to use the current “ORM-D” or “ORM-D AIR” markings, or using the new DOT-authorized “square-on-point” limited quantity marking on parcels containing mailable hazardous material that qualify under the DOT limited quantities provision. The square-on-point symbol marking features black top and bottom corners with a white, or other suitable contrasting background, center portion. The plain square-on-point marking will apply to shipments sent by surface transportation, and the square-on-point marking including the symbol “Y” superimposed in the center will apply to shipments sent by air transportation.
With this revision, the Postal Service will also permit the limited use of some DOT hazardous warning labels in domestic U.S. mail. Previously, parcels bearing any of these labels were prohibited from being entered in the mailstream. With this change, the Postal Service will permit the use of DOT hazardous warning labels on packages that contain substances that meet the current definition of a mailable ORM-D material in hazard class 5 (oxidizing substances and organic peroxides), hazard class 8 (corrosives), and some of hazard class 9 (miscellaneous), when used in conjunction with a DOT square-on-point marking. This marking option for hazard class 9 substances will be limited only to hazardous materials within the ICAO TI Identification Number ID8000, and United Nations (UN) Model Regulations UN3077, UN3082, UN3175, UN3334, and UN3335. With the exception of Identification Number ID8000, the DOT will not be defining a consumer commodity category for these particular hazard classes. Nor will the DOT be defining a consumer commodity in hazard class 4 (flammable solids), but this will not have an impact for USPS® mailers since the Postal Service does not currently permit hazard class 4 material in its air transportation networks.
Under the square-on-point marking option, mailpieces containing currently authorized air-eligible consumer commodities (ORM-D-AIR) within DOT Class 2.2 (nonflammable, nontoxic gasses), Class 3 (combustible liquids), Class 6.1 (toxic substances, poisons, and irritating material), and Class 9 (miscellaneous) will be required to bear the proper shipping name “Consumer Commodity.” These materials will be reclassified as hazard class 9 (miscellaneous) instead of their previous “ORM-D-AIR” classification. Mailpieces containing this material will also be required to bear Identification Number “ID8000.” Mailpieces using this marking option must bear both the DOT square-on-point marking including the symbol “Y” and an approved DOT class 9 hazardous material warning label.
Mailpieces containing mailable air-authorized limited quantity class 9 materials within UN3077, UN3082, UN3175, UN3334, and UN3335, using this marking option, must also bear the proper shipping name “Consumer Commodity” and Identification Number “ID8000,” in addition to the DOT square-on-point marking including the symbol “Y” and an approved DOT Class 9 hazardous material warning label. These are the only Class 9 materials authorized by the DOT to be shipped under the limited quantity provision by air transportation domestically in the U.S. One effect of the alignment of USPS standards and DOT regulations with regards to “limited quantity” class 9 materials is to allow UN 3077 and UN 3082 substances to be mailed under the limited quantity provision. These materials, categorized as environmental hazards, are permitted in substantial quantities for both air and ground transportation by the DOT, but were not accepted for transport by USPS. With this change, these substances may be mailed when prepared in accordance with Publication 52, Packaging Instruction 9C.
Along with the addition of these optional marking standards, the Postal Service expects later to revise its terminology relating to the current ORM-D category. For hazardous material that currently meets the definition of a mailable ORM-D material within hazard classes 4, 5, or 8, and portions of 9, the Postal Service will use the term “mailable limited quantity” and will retain the term “consumer commodity” for the other mailable hazard classes.
Use of these optional marking standards represents a step towards aligning USPS domestic mail marking requirements with those required by the DOT, and will allow mailers who have pre-marked “limited quantity” packaging intended for use with domestic commercial carriers to use this packaging for shipments to domestic addresses by U.S. mail.
Mailing Standards of the United States Postal Service, Domestic Mail Manual (DMM)
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600 Basic Standards for All Mailing Services
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601 Mailability
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10.0 Hazardous Materials
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10.7 Warning Labels for Hazardous Materials
[Revise the second sentence of 10.7 as follows:]
***Except for Division 6.2 materials under 10.17.4, mailable limited quantity hazardous material marked with an optional DOT square-on-point marking under 10.8b, and dry ice under 10.20.4, any hazardous material bearing or required to bear a DOT hazard class warning label under the requirements in 49 CFR is prohibited from mailing.***
10.8 Package Markings for Hazardous Materials
[Revise 10.8 and add a new Exhibit 10.8.b as follows:]
Each mailpiece containing a mailable hazardous material must be plainly and durably marked on the address side with the required shipping name and UN identification number. The following also apply:
a. The UN identification number is not required on a mailpiece that contains an ORM-D material. A mailable ORM-D material must be marked on the address side with “ORM-D” or “ORM-D AIR,” as applicable (or marked under 10.8b), immediately following, or below the proper shipping name. The proper shipping name for a mailable ORM-D material is “consumer commodity.” The designation “ORM-D” or “ORM-D AIR” must be placed within a rectangle that is approximately 6.3 mm (1/4 inch) larger on each side than the applicable designation. Mailable ORM-D materials sent as Standard Mail, Parcel Select, or Package Services must also be marked on the address side as “Surface Only” or “Surface Mail Only.”
b. Optionally, mailable ORM-D material may be marked with an approved DOT limited quantity square-on-point marking (see Exhibit 10.8b). The plain square-on-point marking is used for shipments sent by surface transportation, and the square-on-point marking including the symbol “Y” superimposed in the center is used for shipments sent by air transportation. The following also apply:
1. Markings must be durable, legible, and readily visible.
2. The marking must be applied on at least one side or one end of the outer packaging. The border forming the square-on-point must be at least 2 mm (.08 inch) in width, and the minimum dimension of each side must be 100 mm (3.94 inches), unless the package size requires a reduced size marking of no less than 50 mm (1.97 inches) on each side.
3. For surface transportation, the top and bottom portions of the square-on-point and the border forming the square-on-point must be black, and the center must be white or of a suitable contrasting background. Surface shipments containing qualifying ORM-D material, bearing the square-on-point limited quantity marking, are not required to be marked with the shipping name and identification number.
4. For transportation by aircraft, the top and bottom portions of the square-on-point and the border forming the square-on-point must be black, and the center must be white or of a suitable contrasting background. The symbol ‘‘Y’’ must be black, located in the center of the square-on-point, and clearly visible. Mailpieces intended for transport by air must also be marked with the proper shipping name and identification number, and must also display the appropriate DOT hazardous material warning label (only when required for the hazard class shipped) in accordance with Publication 52.
Exhibit 10.8.b DOT Square-On-Point Markings
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10.12 Gases (Hazard Class 2)
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10.12.4 Marking
[Revise 10.12.4 as follows:]
For surface transportation, packages of mailable gases must be plainly and durably marked on the address side with “Surface Only” or “Surface Mail Only,” and “ORM-D” (or with a DOT square-on-point marking under 10.8b) immediately following or below the proper shipping name (consumer commodity). For air transportation, packages must be plainly and durably marked on the address side with “ORM-D AIR” (or with a DOT square-on-point marking under 10.8b) immediately following or below the proper shipping name, and must also bear a shipper’s declaration for dangerous goods.
10.13 Flammable and Combustible Liquids
(Hazard Class 3)
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10.13.3 Combustible Liquid Mailability
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[Revise 10.13.3a as follows:]
a. For surface transportation, if the flashpoint is 100°F (38°C) but no more than 141°F (60.5°C); the liquid is in a metal primary receptacle not exceeding 1 gallon, or in another type of primary receptacle not exceeding 1 quart, per mailpiece; enough cushioning surrounds the primary receptacle to absorb all potential leakage; the cushioning and primary receptacle are packed in a securely sealed secondary container that is placed within a strong outer shipping container; and each mailpiece is plainly and durably marked on the address side with “Surface Only” or “Surface Mail Only” and “ORM-D” (or with a DOT square-on-point marking under 10.8b) immediately following or below the proper shipping name.
[Revise the first sentence of 10.13.3b as follows:]
b. For surface or air transportation, if the flashpoint is above 141°F (60.5°C) but no more than 200°F (93°C); the liquid is in a primary receptacle not exceeding 1 gallon per mailpiece; enough cushioning surrounds the primary receptacle to absorb all potential leakage; the cushioning and primary receptacle are packed in a securely sealed secondary container that is placed within a strong outer shipping container; and each mailpiece is plainly and durably marked on the address side with “ORM-D” or “ORM-D AIR,” as applicable (or with a DOT square-on-point marking under 10.8b), immediately following or below the proper shipping name.***
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10.14 Flammable Solids (Hazard Class 4)
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10.14.2 Mailability
[Revise the last sentence of 10.14.2 as follows:]
***A flammable solid that can qualify as an ORM-D material is permitted in domestic mail via surface transportation if the material is contained in a secure primary receptacle having a weight of 1 pound or less; the primary receptacle(s) is packed in a strong outer shipping container with a total weight of 25 pounds or less per mailpiece; and each mailpiece is plainly and durably marked on the address side with “Surface Only” or “Surface Mail Only” and “ORM-D” (or with a DOT square-on-point marking under 10.8b) immediately following or below the proper shipping name.
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10.15 Oxidizing Substances, Organic Peroxides (Hazard Class 5)
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10.15.2 Mailability
[Revise the sixth sentence of 10.15.2 as follows:]
***The address side of each mailpiece must be plainly and durably marked with “ORM-D AIR” or “ORM-D,” as applicable (or with a DOT square-on-point marking under 10.8b), immediately following or below the proper shipping name.***
10.16 Toxic Substances (Hazard Class 6, Division 6.1)
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10.16.4 Packaging and Marking
The following requirements must be met, as applicable:
[Revise the second sentence of 16.4a as follows:]
a. ***Each mailpiece must be plainly and durably marked on the address side with “ORM-D” or “ORM-D AIR,” as applicable (or with a DOT square-on-point marking under 10.8b), immediately following or below the proper shipping name.***
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10.19 Corrosives (Hazard Class 8)
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10.19.3 Marking
[Revise 10.19.3 as follows:]
For surface transportation, the mailpiece must be plainly and durably marked on the address side with “Surface Only” or “Surface Mail Only” and “ORM-D” (or with a DOT square-on-point marking under 10.8b) immediately following or below the proper shipping name. For air transportation, the mailpiece must be plainly and durably marked on the address side with “ORM-D AIR” (or with a DOT square-on-point marking under 10.8b) immediately following or below the proper shipping name and must bear a shipper’s declaration for dangerous goods
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10.20 Miscellaneous Hazardous Materials
(Hazard Class 9)
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10.20.3 Marking
[Revise 10.20.3 as follows:]
For surface transportation, the mailpiece must be plainly and durably marked on the address side with “Surface Only” or “Surface Mail Only” and “ORM-D” (or with a DOT square-on-point marking under 10.8b) immediately following or below the proper shipping name. For air transportation, a mailable material must be plainly and durably marked on the address side with “ORM-D AIR” (or with a DOT square-on-point marking under 10.8b) immediately following or below the proper shipping name and bear a shipper’s declaration for dangerous goods.
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We will incorporate these revisions into the next monthly update of the online version of the DMM, which is available via Postal Explorer® at http://pe.usps.com.
— Product Classification,
Pricing, 7-12-12
