HAZMAT Shipping Update.

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The thing that everybody here is overlooking is that to use this limited quantity shipment you must be party status to special permit 7887. You also must have all of the box closure instructions and certification data for the boxes you're using to do hazmat shipping. Most individuals don't have that. Offering a box for shipping without having proper closure. Instructions is the same as offering it for shipping without the proper hazardous materials labels and DOT does audit for that.
Yes, but only if you’re shipping motors and reloads that fall under DOT SP-7887. Ones that are inherently classified as 4.1 do not require being party to the permit. Plus, the permit may not apply to individuals who are not “in commerce”.

Regardless, an individual has to follow the packaging and labeling requirements. Self training in hazmat is allowed.
 
Yes, but only if you’re shipping motors and reloads that fall under DOT SP-7887. Ones that are inherently classified as 4.1 do not require being party to the permit. Plus, the permit may not apply to individuals who are not “in commerce”.

Regardless, an individual has to follow the packaging and labeling requirements. Self training in hazmat is allowed.
A quick look up on the EX number list indicates that all of Estes and all of Aerotech motors are EX classified as 1.4 products. None of them are inherently 4.1 therefore they all must use special permit 7887 and I failed to see how an individual can reclassify something to ship it under a different class without using this permit.
 
A quick look up on the EX number list indicates that all of Estes and all of Aerotech motors are EX classified as 1.4 products. None of them are inherently 4.1. therefore they all must use special permit. 7887
Same thing, none of the EX numbers I have for any of their products are 4.1. All of them are 1.4 or 1.3. I know you know a good bit about these Regulations, so how can an individual ship assuming they have proper packaging materials and have done the proper training and object without using this special permit and reclassified as something it was not tested as?
 
That has nothing to do with the hazmat free shipping though. Those require hazmat fee regardless.
True, but this thread was a general discussion about shipping hazmat, limited quantities, and exemption.

I think you've done well getting all of your shipping processes up to date for your business.

Keep in mind that the DOT requirements are for "in commerce" shipping and do not restrict individuals from hazmat shipping. Individuals do not need formal training, but are expected to follow all of the packaging and labeling requirements. A particular carrier may have other restrictions beyond DOT.

What is not clear is if an individual (not in commerce) needs to apply to be a party to a Special Permit to ship 1.4 as 4.1 (SP-7887) or ship 1.3 as 1.4 (SP-10996).
 
True, but this thread was a general discussion about shipping hazmat, limited quantities, and exemption.

I think you've done well getting all of your shipping processes up to date for your business.

Keep in mind that the DOT requirements are for "in commerce" shipping and do not restrict individuals from hazmat shipping. Individuals do not need formal training, but are expected to follow all of the packaging and labeling requirements. A particular carrier may have other restrictions beyond DOT.

What is not clear is if an individual (not in commerce) needs to apply to be a party to a Special Permit to ship 1.4 as 4.1 (SP-7887) or ship 1.3 as 1.4 (SP-10996).
Correct though I don't see how you could use the limited quantity status that requres the permit(SP7887) without party status as an indiviual. I'm not sure an invidual is able to get party status as the request for party status is for a company specifically.
 
True, but this thread was a general discussion about shipping hazmat, limited quantities, and exemption.

I think you've done well getting all of your shipping processes up to date for your business.

Keep in mind that the DOT requirements are for "in commerce" shipping and do not restrict individuals from hazmat shipping. Individuals do not need formal training, but are expected to follow all of the packaging and labeling requirements. A particular carrier may have other restrictions beyond DOT.

What is not clear is if an individual (not in commerce) needs to apply to be a party to a Special Permit to ship 1.4 as 4.1 (SP-7887) or ship 1.3 as 1.4 (SP-10996).
It's clear enough in 7887, they don't need to be a party to re-ship motors received that were shipped using the special permit but they need to follow all the special permit rules.
Screenshot 2024-02-21 at 12.14.19 PM.png
 
IANAL, but a key point I read into that is that the actual motors being shipped must have been shipped by a party in order to be reshipped by a non-party. So if there's mixing of old/new/other inventory between materials shipped by an entity before/after becoming a party or entities that are party vs. entities non-party, that is a problem.

To illustrate, if AT ships as a party to a distributor that is a non-party, that ships to a retailer that is a non-party, the retailer can ship that newly-received motor to me as a non-party. And if I comply with other requirements, I could reship it as a non-party.

However, if the retailer practices FIFO and ships an old motor that's been sitting on their shelf for years and was shipped from AT before AT was a party, then that retailer cannot ship that motor as a non-party, and I cannot reship it as a non-party. That is the case even if the part number is the same and the contents are identical.

I'd welcome any correction to that understanding.

It would also be interesting and perhaps useful to learn when AT began shipping motors "as a party/grantee." Then, at least one could be sure that if the production date code of a motor is after that date, then it is eligible for reshipment.
 
IANAL, but a key point I read into that is that the actual motors being shipped must have been shipped by a party in order to be reshipped by a non-party. So if there's mixing of old/new/other inventory between materials shipped by an entity before/after becoming a party or entities that are party vs. entities non-party, that is a problem.

To illustrate, if AT ships as a party to a distributor that is a non-party, that ships to a retailer that is a non-party, the retailer can ship that newly-received motor to me as a non-party. And if I comply with other requirements, I could reship it as a non-party.

However, if the retailer practices FIFO and ships an old motor that's been sitting on their shelf for years and was shipped from AT before AT was a party, then that retailer cannot ship that motor as a non-party, and I cannot reship it as a non-party. That is the case even if the part number is the same and the contents are identical.

I'd welcome any correction to that understanding.

It would also be interesting and perhaps useful to learn when AT began shipping motors "as a party/grantee." Then, at least one could be sure that if the production date code of a motor is after that date, then it is eligible for reshipment.
Probably technically true but making that determination conclusively would be next to impossible.
 
but here's the rub: just because the law says you can doesn't mean your shipper has to accept your package. On top of that, if you get the packaging wrong, the penalties are really high. Plus they don't give you a mulligan.

IMHO not worth the effort, aggravation or risk to do myself. My incoming shipments are never small enough to benefit from it, either
 
It's clear enough in 7887, they don't need to be a party to re-ship motors received that were shipped using the special permit but they need to follow all the special permit rules.
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I was going to mention that clause. :) I think the key phrase is "no modifications to the inner packages". If someone keeps the product in the original package (blister pack, tube, etc.), they can ship it using the correct outer package, net weight limit, and markings without being a party to SP-7887. No need to use the original outer package. But, understand DOT regs regarding 4.1 class and Limited Quantity provisions, as well as Fedex/UPS/USPS additional restrictions.
 
I was going to mention that clause. :) I think the key phrase is "no modifications to the inner packages". If someone keeps the product in the original package (blister pack, tube, etc.), they can ship it using the correct outer package, net weight limit, and markings without being a party to SP-7887. No need to use the original outer package. But, understand DOT regs regarding 4.1 class and Limited Quantity provisions, as well as Fedex/UPS/USPS additional restrictions.
I was thinking of the SP10996 clause which is similar but says packages and not inner packages.
 
That's the inner package. The outer would be the shipping box.
That's not what I'm picturing. I'm thinking about a reload with individual grains not exceeding 1.4kg that are each in their own inner packaging. The total grains for the reload in the outer box doesn't exceed 5.6 kg. Per SP-10996. Something like an L or an M reload. Keep that boxed as is and reship it if plans change and the individual needs to send it someplace. Update the paperwork, though. (I'm not thinking of an Overpack).
 
That's not what I'm picturing. I'm thinking about a reload with individual grains not exceeding 1.4kg that are each in their own inner packaging. The total grains for the reload in the outer box doesn't exceed 5.6 kg. Per SP-10996. Something like an L or an M reload. Keep that boxed as is and reship it if plans change and the individual needs to send it someplace. Update the paperwork, though. (I'm not thinking of an Overpack).
If I order an l2200 and an l1420, they're coming in one box. Customer orders 1 L2200, another customer orders 1 L1420, how do I use this permit without party status?
 
If I order an l2200 and an l1420, they're coming in one box. Customer orders 1 L2200, another customer orders 1 L1420, how do I use this permit without party status?
It's clearly ok if the outer box isn't opened and you re-ship the whole package. If an individual orders a single reload sent hazmat according to SP-10966 (from you, for example), they can send it back to you or someone else without opening the box.

What's still unclear (as I mentioned earlier) is if a "not in commerce" individual is allowed to create a new shipment under SP-10966 without being a party to the special permit. The wording in the regs for applying as a party to an SP references invividuals and businesses. So, it would take a request for clarification from the DOT hazmat dept to get a ruling.
 
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