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which will automatically reject cans that exhibit low pressures as a DOT 2S containers must be capable of withstanding without result of a leak, inadequate gassing, or low fill weights. Additionally, bursting a pressure °F one and one-half times the equilibrium cans that exhibit excessively high pressures will also be automati- pressure °F the content at 130 °F. cally rejected by the pressure check method. (iv) Liquid content of the material and gas must not com- Petition for Reconsideration pletely fill the container at 130 °F. The Conference on the Safe Transport of Hazardous Articles (COSTHA) recently submitted to DOT’s Pipeline &Hazardous (v) Except as provided in paragraph (a)(3)(vi) of this Materials Safety Administration (PHMSA) a Petition for Recon- section, each container, after filled, must be subjected to a test sideration, requesting that DOT align itself with the international performed in a hot water bath; the temperature of the bath and standards by changing the U.S. definition of aerosols and permitting the duration of the test must be such that the internal pressure alternate testing to the hot water bath test. reaches that which would be reached at 55 °C (131 °F) or 50 In the Petition for Reconsideration submitted on Sept. 13, 2012, °C (122 °F) if the liquid phase does not exceed 95% of the COSTHA proposed new language that would harmonize the U.S. capacity of the container at 50 °C (122 °F). If the contents are requirements and provide greater flexibility in the testing of glass, sensitive to heat, or if the container is made of plastic material metal and plastic aerosol containers. The preferred text of 49 CFR which softens at this test temperature, the temperature of the §173.306(a), submitted to PHMSA states: bath must be set at between 20 °C (68 °F) and 30 °C (86 °F) but, in addition one container in 2,000 must be tested at the §173.306(a) higher temperature. No leakage or permanent deformation of (3) When in a container for the sole purpose of expelling a container may occur except that a plastic container may be a non-poisonous (other than Division 6.1 Packing Group III deformed through softening provided that it does not leak. material) liquid, paste or powder, provided all of the following conditions are met. Special exceptions for shipment of aerosols (vi) Each outside packaging must be marked “INSIDE in the ORM-D class are provided in paragraph (i) of this sec- CONTAINERS COMPLY WITH PRESCRIBED REGULA- tion. TIONS.” (i) Capacity must not exceed 1 L (61.0 cubic inches). Until the U.S. DOT adopts this proposal, aerosol fillers and ship- (ii) For a metal container, pressure in the container must pers will be subjected to the more restrictive standards in the U.S. not exceed 180 psig at 130 °F. If the pressure in the container It is unfortunate that in today’s regulatory environment, which is exceeds 140 psig at 130 °F, but does not exceed 160 psig at 130 working toward global harmonization, that such a small difference °F, a specification DOT 2P (§178.33 of this subchapter) inside between the domestic and international regulations may have such metal container must be used; if the pressure in the container significant impacts. Perhaps the membership of aerosol industry exceeds 160 psig at 130 °F, a specification DOT 2Q (§178.33a trade groups should submit a similar proposal to the DOT. of this subchapter) inside metal container must be used. In Portions of text from the COSTHA Petition for Reconsideration any event, the metal container must be capable of withstand- have been reproduced in this article and are used with permission from ing without bursting a pressure of one and one-half times the COSTHA. equilibrium pressure of the contents at 130 °F. Steve Hunt is President of ShipMate, Inc., an internationally recog- (iii) For a plastic container, pressure in the container must nized dangerous goods training and consulting firm. Prior to starting not exceed 160 psig at 130 °F. If the pressure in the container is ShipMate, Inc., he was the Chief of the Port Facilities & Container less than 140 psig at 130 °F, a non-DOT specification container Inspection Divisions for the U.S. Coast Guard’s Marine Safety Office may be used. If the pressure in the container exceeds 140 psig in Los Angeles-Long Beach. He helped write many of the current at 130 °F, but does not exceed 160 psig at 130 °F, a specification rules for the transport of dangerous goods, including HM-181 and HM-126F. Hunt is currently developing a series of online training DOT 2S (§178.33b °F this subchapter) inside plastic container courses through ShipMateUniversity.com and HazMatU.org. For more must be used. All non-DOT specification and specification info: +1 (310) 370-3600, steve@shipmate.com. December 2012 Spray 41


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