[pct-l] stove confusion

[Bill Burge]

I'm not sure what the OIA Web New is, but from UPS's site:
http://www.ups.com/content/us/en/resources/ship/hazardous/variations.html

But they still CAN be shipped, via UPS. (It seems, if you can wade your way through their regs AND explain them to some "counter person".)


Here's some clarification on the reference you sent, which gave as its example, Alaska; from the UPS page:

<snip>
Effective January 1, 2011 UPS will no longer accept hazardous materials, including, but not limited to Consumer commodity, ORM-D and combustibles, via UPS Ground service to and from Alaska, Hawaii, Puerto Rico, and Catalina Island. All regulated materials not requiring shipping papers in Air or Ground transport, must be prepared according to air regulations when destined to Alaska, Hawaii, Puerto Rico, and Catalina Island via UPS Ground service.
<snip>


Federal Title 49, which seems to control all of this, has the item classified as "Flammable Gas", "Division 2.1"  173.115:
http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=1cedbca7185be2c4dec827156fd585ab&rgn=div5&view=text&node=49:2.1.1.3.9&idno=49

in section 173.144:
<snip>
Until December 31, 2013 and for the purposes of this subchapter, “ORM–D material” means a material such as a consumer commodity, cartridges, small arms or cartridges, power devices which, although otherwise subject to the regulations of this subchapter, presents a limited hazard during transportation due to its form, quantity and packaging. It must be a material for which exceptions are provided in Column (8A) of the §172.101 Hazardous Materials Table.
<snip>

In Column 8A for both isobutane and propane, is the 306 designation which indicates that exemptions are possible.

My Snow Peak canister is labeled "DOT-E 12274" which maps to their exception:
http://www.phmsa.dot.gov/staticfiles/PHMSA/SPA_App/OfferDocuments/SP12274_2009090425.pdf


I'm not an attorney, but it seems that people have until Dec 2013 to use the current regulations.  Your citation was from 08/2009 and indicates:

> Manufacturers are now working with Outdoor Industry Association to persuade
> DOT to reexamine their interpretation. 

Do you have any follow-up on that?


Bill Burge
bill at burge.com



On Mar 25, 2012, at 8:50 PM, Lance Marshall wrote:

> Bill,
> 
> You are correct that canisters may be mailed through the US Post Office
> provided that it is sent via ground mail and is marked ORM-D (Other
> Regulated Material - Domestic).
> 
> 
> 
> THE 4 ounce limit bantered about for the last couple of years is a
> Department of Transportation (DOT) limit which applies to private carriers
> such as UPS, FedEx, Reddaway Trucking, etc.  The US Postal Service is
> governed by a different section of the Federal Code and is not subject to
> DOT rules.
> 
> 
> 
> Here's the story about the 4 ounce 'revelation'.
> 
> 
> 
>            Loss of HazMat Exemption Raising Shipping Costs for Small Fuel
> Canisters 
> 
> As published in OIA Web News 8/12/2009 
> 
> Retailers may want to bulk up their orders of 4-fluid-ounce
> isobutane/propane fuel canisters in the wake of a recent Department of
> Transportation (DOT) decision that raises the cost of small shipments
> dramatically. They may want to reassess their online sales of the popular
> canisters for the same reason. 
> 
> Shipping some isobutane/propane fuel canisters direct to consumers has
> gotten much more expensive after DOT concluded the industry is not complying
> with the agency's 2002 interpretation of hazmat regulations. In an October,
> 2002 interpretation letter to a manager at Cascade Design's Mountain Safety
> Research (MSR), DOT said that "a mixture of liquefied compressed gases in a
> container of not more than four (4) fluid ounces capacity" could be exempted
> from hazardous material packaging and labeling requirements except when
> shipped by air, in part because the small canisters qualified as a "consumer
> commodity." This allowed fuel shipped in such containers to be reclassified
> as "other regulated material -domestic," or OSM-D, which in turn allowed
> FedEx, UPS and other carriers to waive hazmat fees. 
> 
> When a consumer tried to ship a canister containing 4 fluid ounces of gas to
> Alaska by air earlier this year, however, a DOT inspector measured the
> canister and found it could accommodate 6 fluid ounces. Manufacturers say
> they've been shipping 4 fluid ounces of gas in containers of at least 6
> fluid ounces to allow room for the gas to expand, but DOT has determined the
> larger canisters are not OSM-D compliant. 
> 
> DOT has since inspected several manufacturers and retailers and ordered them
> to start labeling the canisters as a hazardous material. That will add
> $22.50 in hazmat fees to every case of 4-fluid-ounce MSR IsoPro canisters
> shipped through FedEx or UPS, according to Cascade Designs. That's the same
> fee the small package delivery services charge the company for a case of
> 8-fluid-ounce IsoPro canisters, which never had ORM-D status. 
> 
> Manufacturers are now working with Outdoor Industry Association to persuade
> DOT to reexamine their interpretation. In the meantime, dealers ordering
> cases of canisters containing 4-ounces of fuel instead of 8-ounces to avoid
> hazmat fees, need to reconsider how they do business. Cascade Designs said
> it may make sense for their dealers to up the size of their orders to ensure
> the smaller canisters travel by freight. That's because Cascade Design's
> freight providers charge a single hazmat fee whether a shipment contains a
> single canister or several cases of fuel, said a Cascade Designs
> spokesperson. 
> 
> There is a silver lining here for brick-and-mortar retailers as consumers
> buying canisters online will now incur the hazmat fees. In many instances,
> it will be less expensive for them to buy those canisters from local stores
> that have been able to spread the hazmat fee across larger shipments. REI
> has already stopped shipping butane fuel canisters direct to consumers and
> is urging customers to instead buy them at its stores.
> 
> 
> 
> Hope this is useful.
> 
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