HAZMAT Shipping Update.

[manixFan]

Which is exactly why and what I was trying to convey with my post, thank Manix.

Your post was very clear. I think the confusion came later in the thread from the change to not requiring hazmat fees, but still being classified as hazmat. I think some readers, reasonably so, assumed that the motors and reloads were no longer classified as hazmat, and wondered why hazmat training was still required.

Plus, your post was very early in the thread, and as we all know, it's all too easy to jump down to the end of a thread and just read the last few posts and miss something early on. Just the nature of the beast.


Tony

 

[SolarYellow]

I brought the update to Doug’s attention. He emailed me back a few days ago to let me know they had eliminated HAZ from the checkout process. I confirmed that five packs of F15s in my cart gets free shipping.

 

[BEC]

Sounds good. Then I won’t bug Doug about it. Thanks.

 

[tbonerocketeer]

We are working on it. It is a major change as the packaging requirements must be met as well.

 

[John Taylor]

DOT has changed the rules so that A-G motors are no longer hazmat. There are rules, but the gist is, no hazmat restrictions for motors up to 62.5g. Pilfered straight from Aerotech:

AeroTech/Quest has determined and confirmed with the U.S. Department of Transportation (DOT) that previously DOT-approved model rocket motors, rocket motor reloading kits and igniters that are reclassified under special permit DOT-SP 7887 as Flammable solids, organic, n.o.s., Division 4.1, Identification number UN1325, Packing group II may be offered for ground transportation only according to the limited quantity provisions of 49 CFR 173.156, 49 CFR 173.151 and 49 CFR 173.315, under the following conditions:

1. Inner packages may contain up to 1.0 kg (2.2 pounds) net propellant weight capacity each, packed in a strong outer packaging (49CFR 173.151(b)(1)(i)).
2. All outer packaging and gross weight requirements of DOT-SP 7887 must be met including:
   • The outer packaging must not exceed 11.3 kg. (25 pounds) gross weight if no model rocket motors contain more than 30 grams of propellant. The outer packaging shall not exceed 4.5 kg. (10 pounds) gross weight if any model rocket motors contain more than 30 grams, but none contain more than 62.5 grams of propellant.
   • Outer packaging must be UN 4C1 Boxes of natural wood; UN 4D Plywood boxes; UN 4F Boxes of reconstituted wood; or UN 4G Fiberboard boxes.
3. The DOT Limited Quantity (LQ) marking must be applied to each outer packaging (49 CFR 172.315):
4. No other marking or labeling needs to be applied to the outer packaging (49CFR 173.151(b)(1)).
5. No shipping paper is required (49CFR 173.151(d)).
6. A current copy of the DOT-SP 7887 special permit must be maintained at each facility where the package is offered or reoffered for transportation.
7. The model rocket motors and reload kits authorized under this special permit DOT-SP 7887 may be shipped in the same outer packaging with non-hazardous materials needed to construct model rockets.
8. Igniters originally classed as Division 1.4G or 1.4S may be shipped with the rocket motors or reload kits.
9. Multiple outer packages may be overpacked in accordance with the provisions of 49 CFR 173.25.
10. Shipments of limited quantities of division4.1 flammable solids are not subject to placarding requirements (49CFR 173.151(b)(1)).
11. Hazmat fees will not be incurred for packages shipped in this manner via FedEx or UPS.
12. Per DOT-SP 7887: “A person who receives a shipment of model rocket motor kits classed under this special permit but is not a grantee may reoffer the kits for transportation in conformance with this special permit provided no modifications or changes are made to the inner packagings and they are reoffered for transportation in conformance with this special permit and the HMR.”

Basically this means that we will now be able to ship 25 lb. gross weight shipments of model rocket motors that contain no more than 30 grams of propellant each and 10 lb. gross weight shipments of model rocket motors that contain more than 30 grams of propellant each, but no more than 62.5 grams of propellant each, without HazMat labels, HazMat paperwork or HazMat fees providing the DOT Limited Quantity marking is used. Larger size and weight shipments can be made as long as the 10 lb. or 25 lb. inner packs utilize UN approved boxes within an outer pack fiberboard box, which has the DOT Limited Quantity marking applied.

Please see the following links for the actual CFR regulations involved in this interpretation and explanation:

https://www.ecfr.gov/current/title-...ubchapter-C/part-173/subpart-B/section-173.25

https://www.ecfr.gov/current/title-...bchapter-C/part-173/subpart-D/section-173.151

https://www.ecfr.gov/current/title-...bchapter-C/part-173/subpart-D/section-173.156

https://www.ecfr.gov/current/title-...bchapter-C/part-172/subpart-D/section-172.315

Please refer to the Master Motor Matrixfor propellant weights. A copy of DOT-SP 7887 can be viewed here.

Thank you very much!

 

[ATGM]

This is excellent news indeed but I would be curious as to how anyone has implemented these changes without having party status to the 7887 exemption, which is a requirement unless the items are being reshipped just as received from the manufacturer. From my experience so far there is a lot more to it than simply removing a haz fee from the checkout as far as shipping the items is concerned.

You can check to see who has party status here

 

[jadebox]

This is excellent news indeed but I would be curious as to how anyone has implemented these changes without having party status to the 7887 exemption, which is a requirement unless the items are being reshipped just as received from the manufacturer. From my experience so far there is a lot more to it than simply removing a haz fee from the checkout as far as shipping the items is concerned.

You can check to see who has party status here

Yeah ... We got excited when we first saw the announcement from Aerotech, but as we looked into it further it became obvious that it wasn't the panacea we had thought it was.

There are more gotchas than just the 7887 exemption. You also have to be trained to handle haz-mat and there are specific requirements for the boxes used and such.

It does mean that shipments from Estes or Aerotech to us will cost a little less. But it doesn't mean that we can ship more motors without paying for haz-mat ... yet.

 

[rharshberger]

Yeah ... We got excited when we first saw the announcement from Aerotech, but as we looked into it further it became obvious that it wasn't the panacea we had thought it was.

There are more gotchas than just the 7887 exemption. You also have to be trained to handle haz-mat and there are specific requirements for the boxes used and such.

It does mean that shipments from Estes or Aerotech to us will cost a little less. But it doesn't mean that we can ship more motors without paying for haz-mat ... yet.

I just went through my Mod classes for HazMat Shipping (3 modules) that cover everything from basic hazmat to shipping radiactive materials. Most of us really have no idea how tricky HazMat shipping can be, and that it not only covers the product but the shipping container, emergency response, spill cleanup, whos respondsible for what at what stages in the transportation process, and then there are driver requirements on top of all that.

 

[AeroTech]

I can assure you that we are putting far fewer hazmat labels on boxes these days.

 

[JonathanOtt]

How does this affect the hobbyist? For example, I have a few Estes Pro Series II Composite motors (two (2) each of: G80-7T, G40-7W, F50-6T, F26-6FJ) that I want to sell.

Selling local and handing someone the motors is a given, but can I ship them to a buyer across the country (as either a single, or all eight at once)?

 

[speed]

I can assure you that we are putting far fewer hazmat labels on boxes these days.

Working on a Sunday again!

 

[rharshberger]

How does this affect the hobbyist? For example, I have a few Estes Pro Series II Composite motors (two (2) each of: G80-7T, G40-7W, F50-6T, F26-6FJ) that I want to sell.

Selling local and handing someone the motors is a given, but can I ship them to a buyer across the country (as either a single, or all eight at once)?

You cannot, you still need to have the certifications and paperwork to ship them, just because an exemption has been granted does not mean just anyone can ship a hazardous material, its still a hazardous material and still has requirements to ship that must be met. Some of those requirements have been exempted but not all of them which allow for cheaper shipping accommodations but not all of them.

 

[jsdemar]

Limited Quantity DOT regulations.

General:
https://www.ecfr.gov/current/title-...bchapter-C/part-172/subpart-D/section-172.315

See Division 4.1 Packing group II:
https://www.ecfr.gov/current/title-...bchapter-C/part-173/subpart-D/section-173.151

According to Fedex:
https://www.fedex.com/content/dam/fedex/us-united-states/services/HazMat-FXG-shipping-guide.pdf

"Training is mandatory for those shipping hazardous materials, including limited quantity and other exceptions."
"NOTE: Limited Quantity shipments do NOT require the hazardous material shipping paper (OP-900LL or OP-900LG) and hazardous material certification."

Everyone may interpret this differently and should get advice from the DOT and the carrier before proceeding.

 

[cbrarick]

so you still have to be a hazmat shipper trained person. Not worth it for hobbyists You have to pay 150 for the fedex hazmat shipping course. Then you have to spend for the appropriate over packing and inner packing.

 

[Ronz Rocketz]

Gary and I have had hit or miss with receiving the F bulk pack from Estes. We're batting a .500 average. In the last attempt, Scott at Estes said never again. Who knows what internal battles are occurring between the marketing and shipping departments at Estes.

I've received G motor DMS from Jonrocket and Buyrocketmotors. I've gotten LMS from rocket.supplies and RMS H motors from Siriusrocketry with no hazmat charge.

Here's the slide from AT's presentation the other week.

 

[AeroTech]

so you still have to be a hazmat shipper trained person. Not worth it for hobbyists You have to pay 150 for the fedex hazmat shipping course. Then you have to spend for the appropriate over packing and inner packing.

Correct. This is useful for manufacturers, distributors and dealers, but the end user ultimately benefits.

 

[jsdemar]

Referring to:
https://www.phmsa.dot.gov/sites/phm...portation-Training-Requirements-0158-1016.pdf

Q: Does an individual (non-business/private citizen) need hazmat​

training to ship via common carrier (UPS, Fed EX, etc.)?​

A: No. Individuals shipping hazmat by common carrier are not​

required to meet the training requirements under 49 CFR Part​

172 Subpart H unless they are a “hazmat employee” as defined​

in §171.8; however, they are responsible for ensuring that the​

shipment is prepared in accordance with the Hazardous​

Materials Regulations.​

(My interpretation...) Although a private citizen doesn't need to have hazmat training, it's difficult to make sure you're following the regulations without the training. The next thought is to be careful interpreting "non business"; do you ship stuff regularly and make money off it online where it's documented? Does this make it "in commerce" which is required by DOT regulations?

 

[rharshberger]

Referring to:
https://www.phmsa.dot.gov/sites/phm...portation-Training-Requirements-0158-1016.pdf

Q: Does an individual (non-business/private citizen) need hazmat​

training to ship via common carrier (UPS, Fed EX, etc.)?​

A: No. Individuals shipping hazmat by common carrier are not​

required to meet the training requirements under 49 CFR Part​

172 Subpart H unless they are a “hazmat employee” as defined​

in §171.8; however, they are responsible for ensuring that the​

shipment is prepared in accordance with the Hazardous​

Materials Regulations.​

(My interpretation...) Although a private citizen doesn't need to have hazmat training, it's difficult to make sure you're following the regulations without the training. The next thought is to be careful interpreting "non business"; do you ship stuff regularly and make money off it online where it's documented? Does this make it "in commerce" which is required by DOT regulations?

Are you selling it?...if so "in commerce". That way simplified and only part of the story, and you are right without the training its easy to run afoul of the law and these are laws not recommendations as in 49 CFR (Code of Federal Regulations) sections 100-199. The thickest book is about 1.5" thick of thin paper with fine type. The green book is a "quick" reference mainly for HazMat drivers, the Orange book is primarily a quick response guide for emergency responders and drivers. The purple books are the law.

 

[jsdemar]

Are you selling it?...if so "in commerce". That way simplified and only part of the story, and you are right without the training its easy to run afoul of the law and these are laws not recommendations as in 49 CFR (Code of Federal Regulations) sections 100-199. The thickest book is about 1.5" thick of thin paper with fine type. The green book is a "quick" reference mainly for HazMat drivers, the Orange book is primarily a quick response guide for emergency responders and drivers. The purple books are the law.

Regardless of whether you are an individual or a company, you have to comply with the shipping regulations. But you are not banned as an individual from shipping hazmat.

Also, you are not required to pay for formal training. The training requirements, even for an employer and employee, are allowed to be self-taught and self-tested. You must keep a record of it, and refresh every 3 years.

The "Limited Quantity" exemption is much easier to use for shipping. No paperwork. But, you need to understand the hazard classes, the exempt quantities, and the packaging requirements. Standard hazmat shipping requires lots of forms and labels, and knowing how to fill everything out and how to prepare the packaging. Some hazard classes are easier than others. You also need to know what to do if 'something goes wrong'. All of this is online and free for anyone who wants to teach themselves.

 

[cbrarick]

well, you're not sending it via Fedex they won't take hazmat from someone without training. Not sure about the UPS or USPS requirements. it may be a case of you can by law but no shipper will let you.

individuals really have no reason to send haz thru delivery systems: the risk isn't worth it.

We will benefit from aerotech, extes and quest motors in very small quantities being shipped without hazmat charges.

rharshberger: Love your ERG. I have it on my phone along with WISER, because i never carry my erg but generally have my phone :>

 

[rharshberger]

well, you're not sending it via Fedex they won't take hazmat from someone without training. Not sure about the UPS or USPS requirements. it may be a case of you can by law but no shipper will let you.

individuals really have no reason to send haz thru delivery systems: the risk isn't worth it.

We will benefit from aerotech, extes and quest motors in very small quantities being shipped without hazmat charges.

rharshberger: Love your ERG. I have it on my phone along with WISER, because i never carry my erg but generally have my phone :>

I have the WISER app too, as well as the ACGIH app, and the ERG2020 app, HazMat is kind of my way of life on a nuclear cleanup site.

 

[cbrarick]

haha I did nuclear power in the Navy.

as a FF/EMT ERG2020 and Wiser are all we need until you are so deep in the weeds you're on Chemtrack or environmental protection (or clean Harbors)

any time those apps come out, it's gonna be a long, difficult day.......

 

[rharshberger]

haha I did nuclear power in the Navy.

as a FF/EMT ERG2020 and Wiser are all we need until you are so deep in the weeds you're on Chemtrack or environmental protection (or clean Harbors)

any time those apps come out, it's gonna be a long, difficult day.......

Indeed.

 

[jsdemar]

well, you're not sending it via Fedex they won't take hazmat from someone without training. Not sure about the UPS or USPS requirements. it may be a case of you can by law but no shipper will let you.

individuals really have no reason to send haz thru delivery systems: the risk isn't worth it.

Not true. FedEx accepts hazmat from individuals if you schedule a pickup. But you have to know what you’re doing.

 

[cbrarick]

i guess that's a location by location decision. Mine said no.

 

[Zbench]

Not true. FedEx accepts hazmat from individuals if you schedule a pickup. But you have to know what you’re doing.

Its 100% not true. If you sit for their class and get the certificate, you can then call your account rep with proof and they will turn on the feature in your account that lets you ship hazmat. That practically means you can request their 8 part OP-900 form, the self stick envelop it fits in and get the special 1-800 number to their hazmat folks who will walk you through the entire process.

When ammunition primers were through the roof, I did all the above and sold off some of my extensive stash. I called Fedex and they came and picked up my shipments and they all made it to their destination with no issues. Unfortunately, I need to hold on to my copy of the hazmat forms for 20 years in case the DOT ever wants to inspect them (unlikely).

Hazmat regulations for the flammable solids we ship are not that hard to understand. Biggest take aways are understanding how to classify the item, filling out the forms, labelling the box, providing an EX number on the box in addition to a contact number on the form. If you can launch a dual deploy rocket and recover it safely, you can 100% comply with these regulation and ship motors as an individual.

 

[rharshberger]

Its 100% not true. If you sit for their class and get the certificate, you can then call your account rep with proof and they will turn on the feature in your account that lets you ship hazmat. That practically means you can request their 8 part OP-900 form, the self stick envelop it fits in and get the special 1-800 number to their hazmat folks who will walk you through the entire process.

When ammunition primers were through the roof, I did all the above and sold off some of my extensive stash. I called Fedex and they came and picked up my shipments and they all made it to their destination with no issues. Unfortunately, I need to hold on to my copy of the hazmat forms for 20 years in case the DOT ever wants to inspect them (unlikely).

Hazmat regulations for the flammable solids we ship are not that hard to understand. Biggest take aways are understanding how to classify the item, filling out the forms, labelling the box, providing an EX number on the box in addition to a contact number on the form. If you can launch a dual deploy rocket and recover it safely, you can 100% comply with these regulation and ship motors as an individual.

But if you screw up here are your penalties....choose wisely, DOT doesnt give warnings for HazMat....EVER!


The handwritten entries were current as of about a month ago when I attended my cert classes.

 

[jsdemar]

But if you screw up here are your penalties....choose wisely, DOT doesnt give warnings for HazMat....EVER!

Yes, one has to know the risks. Like launching rockets, driving your car, etc.
The shipper will be helpful so that you don't make mistakes. Fedex has called with a correction before.

But Rich is right: it takes a lot to learn the full regulations, and the DOT is the unforgiving Federal Government.

 

[AeroTech]

Gary and I have had hit or miss with receiving the F bulk pack from Estes. We're batting a .500 average. In the last attempt, Scott at Estes said never again. Who knows what internal battles are occurring between the marketing and shipping departments at Estes.

I've received G motor DMS from Jonrocket and Buyrocketmotors. I've gotten LMS from rocket.supplies and RMS H motors from Siriusrocketry with no hazmat charge.

Here's the slide from AT's presentation the other week.

View attachment 630250

It just hit me this morning what the problem may be. The limited quantity protocol we announced last year using DOT-SP 7887 is valid for GROUND TRANSPORTATION ONLY. If someone tried to ship to Hawaii or anywhere else by air, that would open them up to rejected shipments or fines or both.

 

[tbonerocketeer]

Regardless of whether you are an individual or a company, you have to comply with the shipping regulations. But you are not banned as an individual from shipping hazmat.

Also, you are not required to pay for formal training. The training requirements, even for an employer and employee, are allowed to be self-taught and self-tested. You must keep a record of it, and refresh every 3 years.

The "Limited Quantity" exemption is much easier to use for shipping. No paperwork. But, you need to understand the hazard classes, the exempt quantities, and the packaging requirements. Standard hazmat shipping requires lots of forms and labels, and knowing how to fill everything out and how to prepare the packaging. Some hazard classes are easier than others. You also need to know what to do if 'something goes wrong'. All of this is online and free for anyone who wants to teach themselves.

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.