{"id":882374,"date":"2024-06-20T08:00:56","date_gmt":"2024-06-20T12:00:56","guid":{"rendered":"https:\/\/www.thecompliancecenter.com\/ca\/?p=882374"},"modified":"2025-09-05T05:59:50","modified_gmt":"2025-09-05T09:59:50","slug":"do-you-need-training-to-ship-limited-quantities","status":"publish","type":"post","link":"https:\/\/www.thecompliancecenter.com\/ca\/help-center\/articles\/do-you-need-training-to-ship-limited-quantities\/","title":{"rendered":"Do You Need Training to Ship Limited Quantities?"},"content":{"rendered":"

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Do You Need Training to Ship Limited Quantities?<\/h2>\n

One of the best solutions to the headaches involved in the transportation of dangerous goods is to use the \u201climited quantity\u201d option. By keeping individual packages relatively small, the risk is lowered, and some nice exceptions to the regulations become available. But obviously, to use limited quantities, you have to know how this works. How small is \u201csmall\u201d? Are you excepted from all the requirements of the regulations, or only parts of them?<\/p>\n

To know how to ship limited quantities safely, you obviously need to understand the appropriate regulations on them, and that means training. However, requiring full dangerous goods training can be a serious impediment to small package shippers who aren\u2019t part of a larger organization. Let\u2019s say a customer of an online cosmetics company orders an aerosol body spray, but wishes to return it. It could probably go as a limited quantity, but it\u2019s unlikely the customer will have an official hazmat certification. Can they figure the rules out for themselves, or will they have to have official dangerous goods training.<\/p>\n

It turns out our fictional customer will have an easier or harder time depending on how they\u2019re shipping it, and which country they\u2019re in. Let\u2019s take a look at the various options we might encounter in North America.<\/p>\n

Ground Shipment in Canada<\/h3>\n

In Canada, ground shipments fall under the Transportation of Dangerous Goods Regulations (TDGR). Limited quantities are covered by section 1.17<\/a>, and in this case our shipper is in luck. Subsection (2) of this section states that \u201cPart 3 (Documentation), Part 4 (Dangerous Goods Safety Marks), Part 5 (Means of Containment), Part 6 (Training), Part 7 (Emergency Response Assistance Plan) and Part 8 (Reporting Requirements) do not apply to the handling, offering for transport or transporting of limited quantities of dangerous goods on a road vehicle, a railway vehicle or a vessel on a domestic voyage if each means of containment is legibly and durably marked on one side, other than a side on which it is intended to rest or to be stacked during transport, with the mark illustrated in subsection (5).\u201d So, all the shipper has to do is make sure the packaging meets the size and durability requirements of section 1.17, put on the mark that is helpfully illustrated in subsection (5), and no training is required.<\/p>\n

Of course, this does assume that the shipper either is reasonably good at reading regulatory text to understand all the points of section 1.17, or is assisted by someone (perhaps the reverse logistics department of the cosmetics company) who can step them through the procedure. But at least they don\u2019t need to have an official certificate of dangerous goods training to return the shipment.<\/p>\n

Ground Shipment in the United States<\/h3>\n

In most ways, shipment of limited quantities in the United States are similar to those in Canada. The size limits are usually the same (although there are exceptions) and the marking requirements are similar. No hazard labels or placards are required, and limited quantities in most cases do not require hazmat shipping papers in the U.S. However, while the U.S. \u201cHazardous Materials Regulations\u201d in Title 49, Code of Federal Regulations<\/em> (49 CFR) give exceptions from training for many small quantity options, such as excepted quantities they have not done so for limited quantities. So, in our U.S. situation, anyone offering a limited quantity for transport should have to be trained, tested, and certified as required by Subpart H of Part 172 of 49 CFR.<\/p>\n

The U.S. Department of Transportation (DOT) is aware that full hazmat training can be quite a heavy requirement for those who only transport limited quantities. Therefore, it\u2019s currently requesting information from stakeholders to see if training is really necessary for those who never ship anything other than limited quantities or other excepted materials. In the Advanced Notification of Proposed Rulemaking HM-265A<\/a>, the DOT has asked stakeholder shippers and carriers to provide comments on the financial impacts of requiring training for those only involved in limited quantity shipments, versus the probability of an accident occurring that could have been prevented by a training requirement. While there will likely be significant debate on this issue, it would appear that the DOT is at least open to removing the training requirement as they have done for other small quantity and low risk shipments.<\/p>\n

Marine Shipment under the International Maritime Dangerous Goods Code (IMDG Code)<\/h3>\n

While the ground transport regulations in Canada and the U.S. essentially treat limited quantities as \u201calmost\u201d non-regulated, other than the packaging quantity limits and the limited quantity mark on each package, the IMDG Code takes a more restrictive approach. While the individual packages would be treated much like those for ground, the IMDG Code does require them to be listed as dangerous goods on the shipping paper, and even has marking requirements for freight containers that limited quantities. Therefore, the IMDG Code specifically says that limited quantities are still subject to the requirements of Part 1, chapter 1.3, Training. So only trained personnel can offer dangerous goods for transport by ocean.<\/p>\n

Air Shipment under the IATA Dangerous Goods Regulations (DGR)<\/h3>\n

As we usually see, air is the most restrictive of all the modes when it comes to dangerous goods regulation. Under the IATA Dangerous Goods Regulations<\/em> (based on the legal requirements of the ICAO<\/em> Technical Instructions for the Safe Transport of Dangerous Goods by Air<\/em>), limited quantities are essentially treated as regular dangerous goods. The only exception they have from the normal requirements is some packaging relief \u2013 they don\u2019t have to be packed in UN specification packaging. Otherwise, they require full marking and labelling, a full Shipper\u2019s Declaration for Dangerous Goods and, as you might expect, full training for transporting dangerous goods.<\/p>\n

What Do You Need to Do to Comply?<\/h3>\n

So, how do you proceed when shipping limited quantities. If you\u2019re in Canada, and you want to use ground carriers, it\u2019s relatively simple:<\/p>\n