st25

SprayAug14

to change the definition of aerosols. PHMSA indicated that changing the definition would require additional data to better understand the hazard difference between aerosols intended to disperse a liquid, powder or paste and those that solely contain a gas. Specifically, PHMSA request the following: • The number of aerosols manufactured or shipped in a given year in the U.S.; • The percentage of aerosols that meet the criteria for Division 2.1 versus a Division 2.2; • The percentage of product versus propellant; • Testing results, including any burn testing, to see if there is a difference between the two types of aerosols; • Data from the National Fire Protection Association (NFPA) or other standards bodies Other harmonization opportunities Other areas ripe for improved harmonization include aerosol leak testing, the 2P/2Q specifications (which are not aligned with European standards) and limited quantity provisions (there are some disconnects in §173.306 with international regulations). In addition, some regulations have multiple proper shipping names, taking into account every possible variation on the contents and subsidiary risks (e.g. ICAO TI), while others (e.g. UN Model Regulations, IMDG Code) have a single entry in the dangerous goods list and a general lack of clarity with respect to the difference between the definition of an aerosol and small gas receptacles. In the U.S., HMR exceptions for aerosols and packing requirements are found in §173.306. In particular, subparagraphs §173.306(a)(3) and (5) provide exceptions for aerosols in metal and plastic non-refillable containers, while paragraph (i) allows them to be reclassified as ORM-D products. This, of course, will be phased out of the HMR and aerosols will need to be shipped as limited quantities. However, the HMR limited quantity provisions are not the same as those in the UN Model Regulations and international regulations (e.g. IMDG Code). Over the years, §173.306 has become extremely complicated, with requirements for many commodities addressed (e.g. shock absorbers, aerosols, small gas receptacles, refrigerating machines, etc.). It would make sense to create specific packaging sections for each of these commodities to enhance clarity, harmonization, safety and compliance. A rewrite of §173.306 also could take into account the effort of codifying numerous special permits (SP-10232, SP-14188, and SP14286, to name a few) that would result in reducing burden on government and industry and would be consistent with the mandate in the latest hazmat reauthorization bill titled Moving Ahead for Progress in the 21st Century (MAP-21). MAP-21 requires the agency to conduct a review of Special Permits that have been in effect for ten years or more to determine if they can be converted to regulations that take into account the safety record, suitability of the provisions and rulemaking activity in related areas. These Special Permits would certainly fit the criteria. Ultimately, providing harmonized requirements for aerosols would reduce reclassification and marking problems for shipments destined for distribution in other countries and simplify the transportation process for shippers and carriers alike. Spray August 2014 Spray 25 COMMITTED TO SHAPING YOUR PRODUCT’S FUTURE A Partner You Can Rely On For Packaging Designed to Leave a Lasting Impression. Custom Crafted Stand out with packaging uniquely engineered for you. Stunning Design Capture your customer’s eyes and minds. Specialty Shapes Enhance product usability and reinforce your brand. cclcontainer.com


SprayAug14
To see the actual publication please follow the link above