The U.S. Department of Transportation (DOT) hazard class ORM-D will expire on December 31, 2020. ORM-D stands for Other Regulated Material and is a hazard class specific to the U.S. ORM-D is widely used for consumer commodities that are hazardous materials subject to the DOT Hazardous Material Regulations but that present a limited hazard during transportation due to their form, quantity and packaging. DOT defines a consumer commodity as a material that is packaged and distributed in a form intended or suitable for retail sales for consumption by individuals for purposes of personal care or household use. Common examples of ORM-D materials include hairspray, nail polish, aerosol cans of shaving cream, insect repellents, drain openers, and household cleaners.
DOT’s original rulemaking phased out the ORM-D class for air shipments by December 31, 2012 and ground shipments by December 31, 2013. After industry challenged the deadline for ground shipments, DOT extended the deadline to December 31, 2020.
DOT phased out the ORM-D classification in order to align U.S. regulations with international transportation standards, specifically the Limited Quantity exceptions. The Limited Quantity exceptions for highway shipments are very similar to the ORM-D requirements. Like ORM-D shipments, Limited Quantity shipments generally are exempt from the use of UN specification packaging when packaged in combination packagings where the inner packagings meet the specified capacity limitations and are packed in strong outer packagings. The package must be marked on one side or end with the Limited Quantity mark:
Limited Quantity shipments by highway are also exempt from labeling and placarding requirements, as well as from shipping paper requirements provided the materials are not hazardous wastes, hazardous substances, or marine pollutants. Shippers and carriers of Limited Quantity shipments must receive full DOT hazardous materials training.
Companies should ensure that they do not offer any packages marked ORM-D for transportation after December 31st. This may require early shipping of existing stock. DOT has provided verbal guidance that any ORM-D package that is already in transit on January 1, 2021 is allowed to continue to its destination without being subject to enforcement. Shippers that plan to use a Limited Quantity exception in lieu of the ORM-D class should ensure that their packages comply with all of the Limited Quantity requirements, particularly the inner packaging capacity limits and the Limited Quantity mark.