Examples of Limited Quantity Amounts for some Hazardous Substances that are commonly transported

If the smallest container size is less than the Limited Quantity value, and the other conditions described on the Limited Quantity page are met, then parts 3 to 8 of the TDG requirements are waived. However, in certain instances, there are some requirements.


Ethanol and water mixture:
To find information on ethanol, search for it in Schedule 1 of the TDG regulations. The entry for ethanol appears as:

The UN number is provided by a United Nations committee and for ethanol more that 24% by volume it is 1170 (column 1). Solutions with less than 24% ethanol are exempt from TDG regulations.
Column 3 shows that it is class 3 (flammable liquids) and Column 4 shows there are two Packing Groups (PG) (see below) possible for ethanol.
PG II is for ethanol concentrations over 55% by volume and PG III is for ethanol concentrations between 24 and 55%.
Column 6 shows the Limited Quantity Index. For Pg II it is 1 litre and for PG III it is 5 litres.

This means that you could put ethanol solutions in the range of 55 -100% ethanol in containers up to 1 litre in volume (and for ethanol mixtures in the range of 24 - 55% ethanol/water, the maximum container size is 5 litres). In both situations, you could pack several of these containers in a box as long as the total mass of the box was less than 30 kg and you could have several of these <30kg boxes in your shipment.

Note that Column 9 shows the maximum volume of PG II is 5 litres and for PG III it is 60 litres. These are the maximum volumes that could be transported on road or railway vehicle if passengers were also being carried on the vehicle (passengers are people not involved in transporting the product). There should be no problem with the Passenger Index if the vehicle is a privately owned or rental vehicle and all persons in the vehicle are employees who are going to be using the product.

There is another exemption 1.36 Class 3, Flammable Liquids, Alcoholic Beverage and Aqueous Solution of Alcohol Exemption that should apply to mixtures of ethanol and water but the Limited Quantity Exemption for ethanol provides the same exceptions for the TDG requirements.


Formaldehyde Solution:

There are two entries with UN1198 and UN2209 and it is not clear what the difference is. In both cases, they are classed as corrosive (class 8) but UN1198 is also classed as a Flammable liquid (class 3). In both cases, the Limited Quantity is 5L per container. Again you could combine several containers in a box with a total mass less than 30 kg.


Dry Ice: [go to top]
UN1845 is in Class 9 (miscellaneous) and the Limited Quantity is 5 kg. Column 5 shows two special provisions that are listed in Schedule 2. The provisions say that the regulations don't apply to transport via road or rail if the dry ice is packed as a refrigerant in a small package that is marked on the outside as containing dry ice and the packaging allows gas to escape without building up pressure.

Sodium Hydroxide:
Is corrosive (class 8) and the limited quantity for the solid material is 1 kg. For a solution, the quantity is 1 or 5 Litres but it is not clear what the concentration limits are for the two packing groups. As a guess, any solution over 0.5 normal should have a limited quantity of 1L.
Hydrochloric Acid:
is a strong mineral acid and is corrosive (class 8). There are two Packing groups with Limited Quantity of 1 and 5 L but again the acid concentration range for the groups is not specified. As another guess, any solution over 0.5 normal should have a limited quantity of 1 L. Concentrated (undiluted) HCl typically is 11.6 N
Batteries, wet filled with acid [go to top]

Lead acid batteries (UN2794) contain sulfuric acid (about 35% acid/water) and are classed as corrosive (class 8). The limited quantity is 5 (presumed to be 5 litres of liquid inside). I assume a single battery contains less than 5L of liquid so this should fall within the limited quantity value. You could package them as long as the gross mass was <30 kg each and could carry several such packages.

UN2800 is for batteries, wet, non spillable and refers to "sealed" or "maintenance free" batteries. Special provision 39 says that the terminals should be protected from short circuit (this should apply to ALL batteries over 2 volts) and that they should be able to withstand a vibration test and pressure test without leaking. If electrolyte does not leak out of the battery even if the case is cracked, then they are exempt from TDG regulations. Gel type batteries with no free liquid are also exempt.

NB The Alberta Transportation document "Transportation of Batteries and Battery Fluids by Road" (available on this page) states that " wet acid-filled ... storage batteries... cannot be sent as limited quantities or consumer commodities." 
There is no reference to the regulations to support this statement, acid-filled batteries are not excepted from the Limited Quantity Exemption 1.17 and Schedule 1 clearly indicates there is a value under the limited quantity index, column 6.
It thus appears to me that the Limited Quantity Exemption does apply to acid-filled batteries (UN2794).


Propane: [go to top]

Propane is a flammable gas (class 2.1, UN1978) and the limited quantity is 0.125 litre which is not much so the Limited Quantity exemption is not very useful for transporting propane cylinders. However, there are other exemptions that allow propane tanks to be transported on roadways.


Section 1.32.3 Class 2, Gases in Small Means of Containment Exemption
exempts the requirements for Shipping Documentation and Training but the requirements for safety marks, an appropriate container, Emergency Response Plan and reporting spills do apply for:

  • UN1001 acetylene, dissolved
  • UN1002 air, compressed
  • UN1006 argon, compressed
  • UN1013 carbon dioxide
  • UN1066 nitrogen, compressed
  • UN1072 oxygen, compressed
  • UN1978 propane
(these are basically some gases used in welding)
  1. if each container is <= 450 L capacity
  2. no more than 5 containers are being transported
  3. gross mass of all goods <= 500 kg
  4. the containers have labels that are visible from outside the road vehicle


Section 1.15: 150 kg Gross Mass exemption (with respect to propane transport)
are exempt from the requirement for: part 3-shipping documentation, part 4-safety marks, part 5-containment, part 6-training and part 8-Spill reporting 
but require: part 7-Emergency Response Plan if:

  1. transporting on road or rail
  2. gross mass of all dangerous goods is <= 150 kg
  3. for class 2.1 (flammable gas), each cylinder is <=46L capacity

there is also a 500kg exemption in section 1.16 that would require part 6-training, part 7-Emergency Response Plan and 8-spill reporting if:

  1. transporting on road or rail
  2. gross mass of all dangerous goods is <= 500 kg
  3. for class 2.1 (flammable gas), each cylinder is <=46L capacity

So if each propane cylinder was under 46L volume, you could apply parts 1.15 or 1.16. If the cylinders were larger than 46L, you could follow section 1.32.3 rules


Gasoline: [go to top]]

UN1203 is for gasoline which is classed as a flammable liquid with a Limited Quantity index of 30L in a non-passenger vehicle. You could carry several containers of gasoline if each were less than 30L. Gasoline in a fuel tank that supplies the vehicle itself is exempt if the tank is less than 200L.

Under section 1.35, you could carry up to a total of 2000 L of diesel or gasoline fuel if:

  1. the container(s) are secured to the road vehicle
  2. the container(s) are visible from outside the vehicle
  3. the lable or placard on the container is visible from outside the vehicle

under 1.35, you would be exempt from part 3 (shipping documentation) and part 6 (training) but parts 4, 5, 7 & 8 would apply.


Infectious Material: [go to top]

An infectious substance is something that is known or believed to contain viable microorganisms like bacteria, viruses, rikettsia, parasites, fungi or other agents (like prions) that are known or believed to cause disease in humans or other animals. In the laboratory workplace, there are four classes of microbial hazards but for transportation where exposure is much more limited if the material is packaged correctly there are only two Categories: A and B.

Category A are infectious substances that if released could cause a permanent disability or fatal disease to humans or animals. The list of typical viruses and bacteria are in the regulations, part 2-Classificationunder Appendix 3 and includes things like: Ebola virus, polio, Hanta virus, rabies, HIV and anthrax.

Category B include bacteria, viruses and fungi that are less likely to cause injury/death (e.g. hepatitis C & D, influenza, listeria, salmonella and Transmissible Spongiform Encephalopathies (TSE).

There are also standards for securely packaging the infectious material with primary and secondary leak proof containment and sturdy outer package with appropriate labelling. Type 1A and 1B packages are for Category A and B substances and there is a Type 1C packaging for infectious waste material.

Much of these regulations are for medical samples being sent for testing but in our department, we certainly have shipments of things like: microbial cultures, microbial products, genetically engineered organisms, and possible blood, tissue and scat samples from wild animals (of unknown health history) that could contain infectious agents.

Note that the Limited Quantity Index value for both Category A and B materials is zero
This means there is no amount of infectious material that is exempt from the TDG requirements as a Limited Quantity. All parts 3 to 9 apply which means people doing the shipping, transportation and receiving need to be TDG certified.

There are a few other exemptions that might apply if the material is a Biological Product prepared under the Food & Drug Act or if the specimens are believed not to contain an infectious substance but this would not be true for most wild animal specimens.


Section 1.39 Category B exemption
:
You are exempt from the Documentation (part 3) and Emergency Response Assistance Plan (part 7) requirements for category B substances if:

  1. the (outer) container size is at least 100 x 100 mm;
  2. the container complies with type 1B standards with appropriately sized marks;
  3. the container is labled with a shipping name and a 24h telephone number.
however, you are still required to comply with parts 4 (marks), 5 (means of containment), 6 (training),and 8 (Release reporting)


Section 1.4: Biological Products Exemption:

are exempt from the documentation (part 3), marks (part 4), means of containment (part 5), training (part 6), ERAP (part 7) and Release reporting (part 8) if:

  1. the product is prepared according to the Food and Drugs Act,
  2. a type 1B container is used,
  3. the container is labled as "Biological Product" in black letters at least 6 mm high.


Section 1.42 
Human or animal specimen believed not to contain infectious substances Exemption:

Are exempt from documentation (part 3), marks (part 4), means of containment (part 5), training (part 6), ERAP (part 7) and Release reporting (part 8). This requires professional judgment to make this assessment based on knowledge of the medical history and symptoms of the subject the samples are from. While this might apply to samples from animals raised in a clean facility, they are unlikely to apply to samples taken from animals in the wild.

For samples that are exempt, they must be in a Type 1B or 1C secure container marked with the words "Exempt Animal Specimen".

Refer to the TDG regulations and Alberta Transportation publication Transportation of Infectious Substances listed on this page for further details on classifying, packaging and labelling of infectious materials.



Further Information: [go to top]

Packing Groups:
these are categories for the material. Groups I, II and III are for things ranked as very hazardous, hazardous or a moderate hazard and may depend on the concentration of the material (I is more concentrated than III). The maximum container size is affected by the PG designation.
For flammable liquids (class 3), the Packing groups are according to how easy it is to generate vapors that can be ignited (see Flash Point below).
With Corrosives (class 8), the packing groups are divided according to how fast the material damages flesh.

Flash Point (fp):
The flash point is the temperature at which the liquid gives off sufficient vapours to be ignited. Below this temperature, they do not produce enough vapours to from a combustible mixture with the air. The lower the flash point, the easier it is to have a combustible mixture at room temperature. Example: gasoline has a flash point of -38C (which is why it is hard to start your car at -45C) while kerosene has a flash point of +38C. At ambient temperatures, it is harder to start kerosene on fire than gasoline, however, both are flammable liquids. For more information on Flammable and Combustible liquids, go to the Chemical Safety section of this site.