In the world of hazmat transportation, size matters.
Depending on the size of the package that you’re transporting hazardous materials in, many of the hazmat regulations may apply, or you may be exempt entirely for that shipment.
In this quick guide, we’ll explain the difference of both.
Here's what were going to learn. Use the menu to jump to where you want to go.
Many of the hazmat regulations depend on not only on what you are hauling, but how much you are hauling.
This is where the terms bulk, and non-bulk come in.
If you’re in business to make money (that’s why you go through these headaches right?) the more regulations you have to comply with can cost you time and money. And of course, the fewer regulations means that you can get your product and out the door to the end user that much quicker.
Hazmat regulations are a fickle thing.
A quick example is diesel; If it is being transported in a bulk package (like a tanker or some kind of portable tank) there will be a lot of hazmat regulations that will apply to it. If its being transported in non-bulk packages (like a 55 gallon drum) virtually no regulations will apply to it!
Having a basic understanding of these two definitions (they’re easy) can go a long way in helping you make compliance determinations.
Let’s take a closer look at each definition. Once you understand the definition of one, you’ll get the other definition right away. It’s like a two for one special, only not as much fun.
First, I will give you what the regulations says, then I’ll give you a regulation breakdown.
Here's the hazmat bulk packaging straight from the regulations:
Bulk packaging means a packaging, other than a vessel or a barge, including a transport vehicle or freight container, in which hazardous materials are loaded with no intermediate form of containment.
A Large Packaging in which hazardous materials are loaded with an intermediate form of containment, such as one or more articles or inner packagings, is also a bulk packaging. Additionally, a bulk packaging has:
(1) A maximum capacity greater than 450 L (119 gallons) as a receptacle for a liquid;
(2) A maximum net mass greater than 400 kg (882 pounds) and a maximum capacity greater than 450 L (119 gallons) as a receptacle for a solid; or
(3) A water capacity greater than 454 kg (1000 pounds) as a receptacle for a gas as defined in §173.115 of this subchapter.
The first paragraph can be a bit confusing, but we’ll get to it in a moment. The meat and potatoes of what we’re looking for is in paragraphs 1, 2 and 3.
The amount that the portable tank, cargo tank or whatever your putting the hazmat in, must be GREATER than 119 gallons.
Could an inspector take measurements and get a volume for your tank at 119.5 gallons to get you into the regulations? Yep they could, the regulation says “greater than 119 gallons”.
That being said, the real world application or common practice that I’ve seen is, is the nice round figure of 120 gallons. Once the tank is 120 gallons or more, it’s considered a bulk package.
With solid materials (Ammonium Nitrate comes to mind) there are a two pieces of the equation that need to be looked at before you can make a determination about the package a bulk packaging.
The net mass (or net weight of just the material without the package) of the material has to be GREATER than 882 pounds AND a capacity GREATER than 119 gallons.
Both of those numbers must be exceeded before the packaging is considered bulk.
Repeating what I said above, the inspector can work out the math and do 882.5 and 119.5 and that could put the packaging into the bulk definition for a solid. And again, common practice is to round up to the nearest pound or gallon.
For example, to meet the definition of a bulk packaging for a solid, the container would have to be 883 pounds AND a capacity of 120 gallons.
This where a lot of people (inspectors included) get confused about cylinders. The regulations says “water capacity of 1,000lbs”. Whatever the size of the cylinder, in order to be considered bulk it must be able to hold “1,000lbs”.
So to figure how much 1000lbs of water capacity is, let’s take a look at the weight of 1 gallon of water. Using the weight of water as a baseline is pretty common when dealing with hazmat regulations.
1 gallon of water is approximately 8 pounds. It can be 8.3 or 8.4 and also depends on temperature, but we’ll go with 8.3 pounds as a general rule here for discussion.
We just do some simple math and divide the 1,000lbs by 8.3 pounds. When we do that, we come with 120.04 so we’ll just call it 120.
Number look familiar?
120 would be the gallons of water that the cylinder can hold. That number is the same amount it takes to be a bulk package for a liquid, 120 gallons.
If a cylinder can hold approximately 120 gallons of water, then that cylinder would be considered bulk.
So now we have the numbers that everyone is interested in out of the way, let’s go back to the top and breakdown the confusing opening paragraph.
The definition opens by not including vessels or barges but includes transport vehicles and freight containers in the definition that have “no form of intermediate containment”. What does that mean?
It simply means you’re putting the material directly into the package without putting it in something else first. Loading a cargo tank with gasoline or dirt into an end dump trailer are two examples of “no intermediate form of containment”.
The opening paragraph includes “Large Packagings” which have their own definition.
Cargo tank trailers
Some (not all) steel tanks mounted in a pickup truck
Intermediate bulk containers (IBC’s) also known as “totes”
Portable steel tanks
Non-bulk packaging of course, is anything less than the above amounts, however here is the DOT definition just so there's no confusion!
Non-bulk packaging means a packaging which has:
(1) A maximum capacity of 450 L (119 gallons) or less as a receptacle for a liquid;
(2) A maximum net mass of 400 kg (882 pounds) or less and a maximum capacity of 450 L (119 gallons) or less as a receptacle for a solid;
(3) A water capacity of 454 kg (1000 pounds) or less as a receptacle for a gas as defined in §173.115 of this subchapter; or
(4) Regardless of the definition of bulk packaging, a maximum net mass of 400 kg (882 pounds) or less for a bag or a box conforming to the applicable requirements for specification packagings, including the maximum net mass limitations, provided in subpart L of part 178 of this subchapter.
55 gallon drum
Paint cans in a box
Wow, you’ve read down this far you need a medal!
Do you see the two for one special here? Once you learn the definition for hazmat bulk packaging anything less than those numbers are non bulk. So you’ve learned two important definitions for the price of one!
Like I said previously, knowing the difference between whether a hazardous materials packing is bulk or non bulk can determine what your level of hazmat compliance may be.
Whether or not you need to put <dot placards on your vehicle(link to placard article)> is a good example of that
Question or comment? Let me know below. If you’re a hazmat nerd feel free to correct me!
Remember as always, I’m not an attorney I’m publishing this as news and commentary. This has been my interpretation of the regulations based on training and experience. I don’t represent any official entity or organization.
I've been in law enforcement and teaching DOT stuff to inspectors, drivers and companies for over 20 years. When I'm not doing that, I hit the road and travel on my Goldwing.