STEVEN CHARLES HUNT President, ShipMate, Inc. from here to there: topics in transportation Readers are probably already aware that there is a significant difference in how “aerosols” are defined by the U.S. Dept. of Transportation’s (DOT) Pipeline & Hazardous Materials Safety Administration (PHMSA) and the rest of the world. However, just in case, I will highlight this and other differences in the requirements. Different Definitions According to Title 49, Code of Federal Regulations, subchapter C, §171.8, an aerosol is: “…any non-refillable receptacle containing a gas compressed, liquefied or dissolved under pressure, the sole purpose of which is to expel a nonpoisonous (other than a Division 6.1 Packing Group III material) liquid, paste, or powder and fitted with a self-closing release device allowing the contents to be ejected by the gas.” By contrast, the U.N. Model Regulations, International Maritime Dangerous Goods (IMDG) Code, International Civil Aviation Organization (ICAO) Technical Instructions for the Transport of Dangerous Goods by Air and other regulatory references define an aerosol as: “non-refillable receptacles meeting the provisions of the packaging regulations, made of metal, glass or plastics and containing a gas compressed, liquefied or dissolved under pressure, with or without a liquid, paste or powder, and fitted with a release device allowing the contents to be ejected as solid or liquid particles in suspension in a gas, as a foam, paste or powder or in a liquid state or in a gaseous state.” Consequently, this may present some serious issues when importing or exporting certain compressed gases such as butane cartridges and lighter refills, refrigerants (e.g., 1,1,1,2-tetrafluoroethane) and spray dusters. For example, under the provisions of the IMDG Code, R-134a (1,1,1,2-tetrafluoroethane) may be re-classed and described as UN1950, AEROSOLS, 2.2 and offered as a limited quantity when in metal receptacles of not more than one liter in volume. However, that very same product could not be offered as a limited quantity in receptacles between 120–1000mL. In the U.S., Title 49 CFR 171.23(b)(1) permits the IMDG Code to be used within the U.S., but specifically requires that compressed gases be limited to 4 fl. oz. (120mL). Title 49 CFR §171.23(b)(1) states: “Except for a limited quantity of a compressed gas in a container of not more than four fluid ounces capacity meeting the requirements in § 173.306(a)(1) of this subchapter, the proper shipping name “Aerosol,” UN1950, may be used only for a non-refillable receptacle containing a gas compressed, liquefied, or dissolved under pressure the sole purpose of which is to expel a nonpoisonous (other than Division 6.1, Packing Group III material) liquid, paste, or powder and fitted with a self-closing release device (see § 171.8).” It is interesting to note, however, that the IMDG Code limits UN3159, 1,1,1,2-TETRAFLUORETHANE, 2.2 to 120mL in order to take advantage of the limited quantities. Although this quantity limitation is consistent with 49 CFR subchapter C, the IMDG Code allows you to reclassify the product as an aerosol, thereby enjoying the “added” volume, whereas 49 CFR does not. Alternative Water Bath Testing Another important difference between 49 CFR subchapter C and the international standards, based on the U.N. Model Regulations, is the option of an alternative to the hot water bath test. The IMDG Code, for example, in section 6.2.4.2.2 of the 36th Amendment, permits alternative methods which provide an equivalent level of safety, with the approval of the competent authority, and which conform to the requirements outlined in the subsequent sections of the Code. Provided the requirements of 6.4.2.2.2 are met, and the competent authority has authorized the alternative test method, aerosols outside the U.S. need not be tested in a hot water bath. The requirements include a quality system, pressure and leak testing before filling and testing of the aerosol after filling. For convenience, I have transcribed the requirements below: Quality system (6.2.4.2.2.1) Aerosol dispenser fillers and component manufacturers shall have a quality system. The quality system shall implement procedures to ensure that all aerosol dispensers that leak or that are deformed are rejected and not offered for transport. The quality system shall include: a) a description of the organizational structure and responsibilities; b) the relevant inspection and test, quality control, quality assurance and process operation instructions that will be used; c) quality records, such as inspection reports, test data, calibration data and certificates; Take a Bath Before You Take a Bath… 80 SPRAY July 2014
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