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Consumer Commodities Compliance Checklist


Under the new laws, if you should be shipping under Limited Quantity and your package fails, you will be fined by the PHMSA. This is now a recordable incident, whereas ORM-D package failures were not. Here is a brief checklist of things you should review within your packaging systems for shipping hazardous materials to comply with the new rules.

Understand the rule changes.


Moving to the limited quantity exception is not a difficult task, but it will require some attention to what detail is present within current documentation. And making the necessary changes to update that documentation. Then of course, training your employees to these changes.


  • PHMSA – Rulemaking HM-215K
  • NPRM (May 25, 2012) – Proposed changes to HM-215K


Review package markings and labeling.

PHMSA eliminates the ORM‐D marking on packages as of January 1, 2014 for surface transport and January 1, 2013 for air transport. Note: A 5/25/12 Notice of Proposed Rule Making (NPRM) proposes extension of the permissible use of the ORM-D marking for surface transport to January 1, 2015.


  • Domestic ‐ The new surface limited quantity mark (without the “Y”), required by the HMR for all surface shipments (road, rail, and vessel) of limited quantities is acceptable for use immediately. For air shipments, the Y limited quantity mark is required. As a reminder, shipments packed in compliance with the air requirements and marked with the Y limited quantity mark are acceptable for carriage by highway, rail car, or vessel.
  • International – The 35th Amendment of the IMDG Code and the 2011‐2012 ICAO TI adopted the new limited quantity marks, eliminating the previous UN number inside a diamond. Therefore, all limited quantity shipments prepared in accordance with either the IMDG Code or the ICAO TI must have the new limited quantity mark as appropriate by mode. And with the US DOT transitioning consumer commodities (ORM-D) to the limited quantity mark, further global harmonization is achieved.

Review component documentation.

  • Do you, the shipper of the package, have records that prove that package components are made in the same way, to the same specifications, all the time? Any changes to a package design would require retesting to prove capability. So, this becomes a way to verify that all packages should perform capably, all the time.
  • Are your suppliers on board to maintain these records, and produce the package system components the same way, all the time? This is actually easier than it seems, it just requires someone to actually check, and make the supplier responsible for it.


Check your packaging stock.

  • Dual markings (to update your existing outer containers) are allowed until the dates noted, but not after. Plan your packaging stock accordingly.
  • Also, note that as stated above, any changes in packaging components will require testing to prove capability of meeting conditions normal to transport. See testing below.

Review packaging testing and documentation.

  • If you have no test documents, in 49 CFR 178.601(a) the first sentence reads, “(a) General. The test procedures prescribed in this subpart are intended to ensure that packages containing hazardous materials can withstand normal conditions of transportation and are considered minimum requirements.” 
  • We encourage customers to consider using PG II performance test levels as a baseline for testing the capability of their package systems. 


Train your employees.

  • All employees are to be trained by their employer (49 CFR 172.700). The employees are to be trained and tested every three years, or when the regulations change.
  • Topics you'll probably want to cover include these. Work with a reputable training company to be sure you are offering the proper training to each type of hazmat employee according to his or her function in your company.
    • 49 CFR, Part 172.704 for certification in hazardous materials handling and transportation.
    • Basic safety elements including recognition and identification of hazardous materials as required by the DOT regulations and the Hazard Communication Standard.
    • Basic operations required for handling emergencies involving hazardous materials.
    • Basic knowledge of the Hazardous Materials Table (49 CFR 172.101), Labels and Placards, and Shipping Papers.
    • Associating the nine DOT hazard classes with the appropriate placards for use in transportation.
    • Identifying the specific type of packaging group for a particular type of shipment.
    • Identifying the specific types of packages that can be used with each packaging group.
    • Understanding what exceptions negate the need for these packaging requirements.
      Identified forbidden materials and packaging.
    • An awareness of security risks associated with hazardous materials transportation (HM-232).
    • How to recognize and respond to possible security threats.


Get help.

  • Call us at 800.413.8867 to speak with a Dangerous Goods Packaging Consultant. We've helped numerous customers review their current packaging, testing, documentation, training, and more. Or if you prefer, complete our online form and we will be in contact.