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from here to there: topics in transportation Steven CharleS hunt President, ShipMate, Inc. Small Differences May Have Significant Impacts Fments with respect to the definition and testing of aerosols. the volume of each can to no more than 4 ounces (120 ml). Con-sequently, distributors of larger size receptacles must regulate thesegoods as UN3159, 1,1,1,2-Tetrafluoroethane, 2.2, thereby incurring-ew people realize that there is a small but significant differencebetween the U.S. domestic and the international require The subtle difference in the definition of aerosols between the U.S. additional costs for packaging, marking and labeling, documentation Dept. of Transportation’s Hazardous Materials Regulations (HMR) and, in many cases, hazardous materials surcharges. and the international dangerous goods standards, coupled with Although there are a number of DOT Special Permits (e.g., DOT- more restrictive aerosol testing requirements may have a significant SP 11516, DOT-SP 14188) that allow larger receptacles containing impact with respect to marking, labeling, packaging, documentation R-134a or R-152a (1,1-difluoroethane) to be reclassified and offered and, ultimately, cost. for transport as Consumer Commodity, ORM-D, these special per- mits are difficult and costly to obtain. Definitions The U.S. Dept. of Transportation (DOT) defines an aerosol as: “… Testing Requirements any non-refillable receptacle containing a gas compressed, liquefied The provisions of 49 CFR §173.306(a)(3) and (5) provide specific or dissolved under pressure, the sole purpose of which is to expel a exceptions to the packing and hazard communication requirements non-poisonous (other than a Division 6.1 Packing Group III materi- for aerosols (gases used to expel a liquid, paste or powder), pro- al) liquid, paste, or powder and fitted with a self-closing release device vided that the aerosol is in a metal container, within the prescribed allowing the contents to be ejected by the gas. pressure ranges at specific temperatures, and subjected to a test ”The U.S. definition in 49 CFR subchapter C is not consistent performed in a hot water bath, where the temperature of the bath with the international definition of an aerosol found in the United and the duration of the test must be such that the internal pres- Nations Model Regulations, the International Maritime Dangerous sure reaches that which would be reached at 55°C (131°F) (50°C Goods (IMDG) Code, the International Civil Aviation Organization 122°F if the liquid phase does not exceed 95% of the capacity of Technical Instructions on the Safe Transport of Dangerous Goods the container at 50°C 122°F). If the contents are sensitive to heat, by Air (ICAO TI) and the Regulations governing European Road the temperature of the bath must be set at between 20°C (68°F) and Transport (ADR). 30°C (86°F) but, in addition, one container in 2,000 must be tested The international definition of an aerosol (or aerosol dispenser) at the higher temperature. is “…a non-refillable receptacle meeting the requirements of 6.2.4, It is important to note that many aerosols are also subject to made of metal, glass or plastics and containing a gas, compressed, U.S. Food & Drug Administration (FDA) requirements that limit liquefied or dissolved under pressure, with or without a liquid, paste or filling and testing conditions, which could introduce bacteria or powder, and fitted with a release device allowing the contents to be other harmful contaminants into the container or product. Hot ejected as solid or liquid particles in suspension in a gas, as a foam, water baths can create ideal conditions for bacterial growth without paste or powder or in a liquid state or in a gaseous state. additional disinfection methods, which are costly and potentially For example, a commonly shipped product, 1,1,1,2-Tetrafluoro- harmful to the containers themselves. Therefore, the hot water bath ethane (refrigerant gas R-134a), may be reclassified and shipped test, as a form of leak/pressure testing, may actually create an unsafe internationally as UN1950 Aerosols, 2.2 if the gas is contained condition. within a non-refillable metal, plastic or glass container and fitted 49 CFR §173.306(a)(5)(v) provides an alternate test method for with a release device allowing the contents to be ejected. However, plastic aerosols containing a Division 2.2 gas. This alternate test in the U.S., the more restrictive U.S. definition requires the product includes both a pressure and leak test before filling, and a weight to be offered as UN3159 1,1,1,2-Tetrafluoroethane, 2.2. The non- and leak test after filling. Under the current U.S. requirements, the bulk packaging requirements for UN3159, found in Title 49, Code alternate testing is limited to plastic aerosols containing a Division of Federal Regulations §173.304(d), require cylinders to comply 2.2 gas with no subsidiary risk. However, under the international with the provisions of 49 CFR §173.304a, or be packaged in a DOT standards (section 6.2.4.2.2 of the UN Model Regulations), the 2P or DOT 2Q container. This section further limits the filling ratio alternate testing method is permitted for all aerosols including metal to no more than 87%. Although there are exceptions to the pack- aerosols when recognized by competent authorities, provided a qual- ing requirements in 49 CFR §173.306, the provisions that allow ity assurance program is in place. Alternate testing methods include this commodity to be reclassified as a Consumer Commodity limit an automated pressure check (100% inspection on each container), 40 Spray December 2012


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