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hot water baths require large amounts of energy, while the must be supplied and maintained at every facility where the proposed alternative requires very little, many reports include an product is available for further transportation. This places a heavy environmental commentary. The reports can be directed to the burden on the marketer, who generally loses control of the product Associate Administrator for Hazardous Materials Safety, Pipeline after the first shipment. It is thought that retail stores will not & Hazardous Material Safety Administration, U.S. DOT, East have to maintain such files unless store-to-store shipments are Building PHH-30, 1200 New Jersey Ave., SE, Washington, D.C. contemplated. 20590. Most Special Permits specify that BOV products meeting the Instructions, including those for renewals, are provided in Title “Consumer Commodity” definition may be re-classified and shipped 49, CFR, Section 107.109. The submissions are first reviewed by a as ORM-D. However, since the ORM-D option will become extinct technical staff, then sent for legal approval, after which the Special in 2014, a procedural change will be forthcoming. Permit is prepared according to established protocols, duly signed Section Nine may limit the mode of transportation to motor by or for the Associate Administrator and mailed to the applicant. vehicles. This would appear to eliminate transport by train, ship The process generally takes several months if everything goes and air. Many fillers, who routinely air freight statistical samples to smoothly. Revisions and renewals can also take several months. distant marketers, would have to discontinue this option and send the samples only by truck. For some S.P.s several types of carriers are DOT PHMSA Special Permit Analysis authorized. Under Section Ten, all carriers must carry a copy of the The Special Permits (S.P.) are divided into 12 sections. The first Special Permit. simply identifies the grantee, by name and city address. The Section Eleven provides details of the sanctions available to the second will typically report what the S.P. authorizes, such as the U.S. DOT for persons who violate any of the above rulings. It transportation in commerce of an aluminum “DOT Specification also describes the required training of “HazMat employees,” with 2P” can which has been tested by an alternative method, in lieu reference to pphs. 172.700 through 172.704. of the hot water bath, and has been subjected to an automatic Finally, Section Twelve lists reporting requirements, in case any pressure test on the production line. No other relief from the shipping or other problems result from the production of Special Hazardous Material Regulations (HMS) is authorized. The safety Permit BOV dispensers. The Associate Administrator (HMS) must analysis performed on the product relates only to transportation, be immediately notified in writing. Here it can be noted that any not to consumer use. Lastly, the S.P. will be given either “no party aerosol accident involving injury or death must be reported to the status” or “party status.” In the latter case firms other than the Consumer Product Safety Commission (CPSC) as well. applicant may use it beneficially. Sections Three and Four contain brief descriptions of the affected Conclusions regulatory system and the fact that the product is exempted from The Special Permits (no longer to be called exemptions) are 49 CFR pph. 173.306(a)(3)(v). Section Five gives the basis of now valid for two years, and renewals are effective for four the exemption: a report by the applicant. Section Six restricts years. Revised documents must be issued if there is any change the propellant to nitrogen (or compressed air) and the dispenser in formula, fill volume or packaging. While some fillers would capacity to one liter. Section Seven considers safety control welcome a broad, generalized Special Permit allowing BOVs measures. The BOV dispenser is described and the contents are to avoid the hot water bath step, others feel that either a pph. identified as non-hazardous and of a stipulated fill volume. More 173.306 regulatory re-write or the inclusion of a small hot tank in than one dispenser and fill volume can be covered, but for each the production line may be a less burdensome option. size the agency also describes a nominal pressure. For example, a Approval of hot water bath alternatives for nitrogen or CAIR product fill can be depicted as 100mL (6.1 cubic inches), and the containing BOV products may have future consequences. For pressure as nominally 106 psi-g. Presumably the temperature is instance, since these gases are essentially insoluble in water-based ambient, such as from about 20° to 30°C (68° to 86°F). It is not products (like air fresheners) the same Charles’ Law pressure- listed because, in this example, the nitrogen pressure will rise by temperature relationship will occur, with or without the bag. The only about 0.03 bar per degree C. (0.24 psi. per degree F.), making pressure increase upon hot-tanking would be equally small—in the the temperature effect de minimus. range of only about 0.7 to 0.9 bar (10 to 13 psi.) for both BOV and Section Seven continues with a description of operating controls non-bag versions, depending on their initial pressure. The BOV and testing requirements. Two aspects are important here. An does allow “continuous spraying,” which is not available with the acceptable pressure range is established, which may be as restrictive non-bag option unless a “360-degree” valve is utilized. Could the as +/-0.345 bar (+/-5.0 psi.) for smaller containers. In the above hot water bath be eliminated for certain “nitrosol” (nitrogen or example, this would limit acceptable pressures to the range of 101 CAIR based) formulations? to 111 psi-g. Considering the somewhat limited accuracy of the Avoidance of hot water bathing by Special Permit is not restricted automatic pressure checker, the temperature and other factors, to BOV dispensers. For example, in SP 13292, certain plastic this range may be hard to always meet. It may have simply been aerosol containers up to 887 mL in capacity are approved if they given to the PHMSA by the applicant, based on laboratory and contain a non-flammable (Division 2.2) propellant, have a content engineering studies. The range could have been easily doubled with pressure not to exceed 10.34 bars (150 psi-g.) at 54.4°C. (130°F) no adverse effect upon safety or product integrity. In any event, and do not burst below 14.48 bar (210 psi-g.). Other restrictions Section Seven also requires the manual pressure testing of BOV also apply. dispensers every 30 minutes, with further requirements and possible The aerosol industry is currently considering recommendations sanctions if out-of-range units are found. to re-define the term “aerosol,” the use of alternatives to hot water Section Eight requires that BOV dispensers must be marked baths, that BOV products should not be classified as aerosols and, with the Special Permit number (e.g. DOT SP 12345). See pph. linked to that, the use of volumetric labeling for them, instead of 172.301(c). The outer shipping containers must also be marked contents by weight. It will be interesting to see how these challenges with the number. More onerously, a current copy of the permit to the present systems develop during the next year or two. SPRAY December 2012 SPRAY 27


SprayDec12
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