Whether a packaging is considered bulk or non bulk according to PHMSA/DOT is determined primarily by the capacity of the packaging. You can use the chart below to find a quick answer and continue reading below the chart for a more detailed analysis.

TLDR Chart
Bulk Non-Bulk
Liquid Greater Than 119 Gallons Less Than or Equal to 119 Gallons
Solid Greater Than 882 Pounds Less Than or Equal to 882 Pounds
AND capacity Greater Than 119 Gallons AND capacity Less Than or Equal to 119 Gallons
Gas Water Capacity Greater Than 1000 Pounds Water Capacity Less Than or Equal To 1000 Pounds

 

Bulk Packaging Definition

CFR 49 Part 171.8 “Hazardous Materials Definitions” defines Bulk Packaging as follows:

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.

In other words a vessel or a barge (i.e. watercraft) can not be considered bulk, but a transport vehicle, freight container with no intermediate form of containment (tanker car), or large packaging can be considered a bulk packaging. Furthermore, a packaging is considered bulk when it can possibly contain liquids in excess of 119 gallons OR, when transporting solids, when it does contain more than 882 pounds and can possibly contain more than 119 gallons of liquid.

 

Non Bulk Packaging Defintion

CFR 49 Part 171.8 “Hazardous Materials Definitions”defines Non-bulk packaging

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; or

(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.

More simply put, anything that doesn’t meet the definition of bulk packaging is considered non-bulk packaging.

 

The requirements for shipments of bulk packages varies greatly from that of non-bulk packages. Make sure you’re following the correct set of rules and as always if you have any questions please comment below.