Confused by the DOT definition of bulk and non-packages? In this article we give you a simple breakdown to help you understand bulk vs non bulk hazmat definitions.

Being familiar with these definitions will help you to not only select the packaging your product should be in, but what hazardous materials regulations are going to apply to the shipment.

Bulk vs Non-Bulk Hazmat At a Glance

Here’s a quick reference chart to determine bulk and non bulk packaging rule.

	Bulk Packaging	Non-Bulk Packaging
Liquid	Greater than 119 gallons	Equal to or less than 119 gallons
Solid	Greater than 882 pounds	Equal to or less than 882 pounds
	AND a Capacity greater than 119	AND capacity equal to or Less Than 119 Gallons
Gas	Water Capacity Greater Than 1000 Pounds	Water Capacity Less Than or Equal To 1000 Pounds

Bulk packaging definition

According to the hazardous materials regulations (edited):

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:

A maximum capacity greater than 450 L (119 gallons) as a receptacle for a liquid;
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
A water capacity greater than 454 kg (1000 pounds) as a receptacle for a gas as defined in §173.115 of this subchapter.

Follow this link to read the definition of both bulk and non-bulk here.

Bulk package breakdown

Let’s take a moment to breakdown each of the paragraphs shown in the bulk definition in 171.8. Most of what we’ll be discussing is contained in paragraphs 1, 2, and 3.

The amount or capacity of the bulk packaging (ex. portable tank, cargo tank, IBC) or whatever your putting the hazmat in, must be GREATER than 119 gallons.

Often, people get confused with this, and assume that because the container or packaging they have is right at 119 gallons, that it’s considered bulk. The keyword in the definition is “greater than”.

All that said, the real world application or common practice that’s typically used is, is the nice round figure of 120 gallons. Once the tank is 120 gallons or more, it’s considered a bulk package.

Solids

With solid materials (Ammonium Nitrate comes) there are a two pieces of information need to be looked at before you can make a determination about whether a package containing solids is bulk.

For solids, two values must be met;

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.

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.

Gases

This where a lot of people (and some inspectors) get a bit confused about cylinders. The regulations says “water capacity Greater than 1,000lbs”.

Let’s take a closer look at cylinders.

Water Capacity for cylinders

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 common when dealing with hazmat regulations.

1 gallon of water is 8.34 pounds. We just do some simple math and divide the 1,000lbs by 8.34 pounds. When we do that, we come with 119.90, which would be over 119 gallons.

119.9 would be the gallons of water that the cylinder can hold, which makes the cylinder a bulk package.

Bulk or Non-bulk Cylinder? Here’s the easy way to tell

Two of the most common cylinders that are in wide use are the DOT 3A and DOT 3AA. These cylinders are a seamless steel cylinder that are in wide use from welding and repair business to filling up birthday balloons at the local Wal-Mart.

If you look at the neck area of the cylinder near the valve, it should be stamped with identification information. Part of that information is what DOT standard the cylinder was built to.

In the case of either a DOT 3A or DOT 3AA cylinder, if the letter “X” appears, the cylinder is a bulk cylinder. For example “DOT 3AX or DOT 3AAX“.

Examples of hazmat bulk packaging containers

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
UN portable tanks (ISO tanks)

What is the definition of non bulk packaging?

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:

A maximum capacity of 450 L (119 gallons) or less as a receptacle for a liquid;
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;
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
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.

Examples of a non bulk packaging

55 gallon drum
Paint cans in a box
Most cylinders
Limited quantities
Plastic bottles of printers ink

Need Help Making Sense of Hazmat Rules?

If you need help with your hazmat training give us a call at 904.426.4951 or contact us and we’ll be happy to help get you started on hazmat training.

Bulk vs Non Bulk Hazmat: Do You Know The Difference?