32 Spray April 2015 Steven Charles Hunt President, ShipMate, Inc. from here to there: topics in transportation Transport in Australia In the January issue of Spray, I had described some of the standards for exporting and transporting aerosols and other dangerous goods into Mexico. In this issue, I will share with you some of the country-specific nuances and regulatory requirements for exporting and transporting aerosols and certain other dangerous goods into and within Australia. The latest revision to the Australian Dangerous Goods (ADG) Code, Revision 7.3, was published in August 2014 and applies to all jurisdictions within Australia. The ADG was updated to conform to the latest technical requirements for the land transport of dangerous goods across Australia and takes into account the 11th Revised Edition of the United Nations Recommendations on the Transport of Dangerous Goods Model Regulations. There are a number of Australia-specific requirements that have been retained in the latest ADG update, so a detailed review of these requirements should be conducted before exporting aerosols and certain other dangerous goods “down under.” Standards ADG7.3 adopts the structure, format, definitions and concepts of the Recommendations on the Transport of Dangerous Goods Model Regulations, 17th Revised Edition (2011) while retaining some Australia-specific provisions. The ADG Code provides detailed technical specifications, requirements and recommendations applicable to the transport of dangerous goods in Australia by road and rail, which are consistent with the United Nations’ Model Regulations (UN Orange Book). Dangerous goods consignments shipped to Australia by vessel or air must conform to the International Maritime Dangerous Goods (IMDG) Code or International Civil Aviation Organization (ICO) Technical Instructions for the Transport of Dangerous Goods by Air (respectively), in addition to any carrier-specific restrictions that may apply. The Australian definition of aerosols or aerosol dispensers as “… non-refillable receptacles meeting the requirements of ADG Section 6.2.4, 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” is consistent with the UN’s Model Regulations but is not consistent with the U.S. definition of aerosols, which 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.” Accordingly, certain dangerous goods that may qualify as “aerosols” within Australia must be appropriately described by their fully regulated basic description when exported from the U.S. Notable examples include replacement refrigerants and dusters. With respect to the classification of aerosols, ADG Code Special Provision 63 requires that: • Division 2.1 applies if the contents include 85% by mass or more flammable components and the chemical heat of combustion is 30 kJ/g or more; • Division 2.2 applies if the contents contain 1% by mass or less flammable components and the heat of combustion is less than 20 kJ/g; • Otherwise, the product must be classified as tested by the tests described in the Manual of Tests & Criteria, Part III, Section 31. Extremely flammable and flammable aerosols must be classified in Division 2.1; non-flammable in Division 2.2; • Gases of Division 2.3 must not be used as a propellant in an aerosol dispenser; • Where the contents other than the propellant of aerosol dispensers to be ejected are classified as Division 6.1 packing groups II or III or Class 8 packing groups II or III, the aerosol will have a subsidiary risk of Division 6.1 or Class 8; • Aerosols with contents meeting the criteria for packing group I for toxicity or corrosivity are prohibited from transport; and • Subsidiary risk labels may be required for air transport. With respect to limited quantities, ADG Special Provision 277 requires that aerosols containing toxic materials are limited to 120mL per inner receptacle, while all other aerosols are limited to 1000mL per inner receptacle. The total gross mass of each completed package may not exceed 30 kg (66 lbs). Additional exceptions apply to small aerosol receptacles having a volumetric capacity less than or equal to 50mL (1.69 fl oz). Marking & Labeling Requirements With respect to packaging, marking, labeling and documentation, the requirements of the ADG Code 7.3 are essentially identical to those of the Hazardous Material Regulations (HMR), IMDG Code and ICAO Technical Instructions. Packaging must conform to the UN Performance Oriented Specification Packaging standards for other than limited quantities. Packages must also be properly marked and labeled with the proper shipping name, UN identification number and corresponding primary and subsidiary risk labels, if applicable. Aerosols in limited quantities offered for surface transport (road/rail) or by vessel need only be marked with the Limited Quantity (hollow diamond) marking as outlined in ADG Code 7.3, section 3.4.7. A smaller limited quantity marking (50 mm x 50 mm) is authorized for smaller outer packaging whose dimensions will not accommodate the diamond-shaped marking. Additional Aerosol Marking Requirements All aerosols should be marked in accordance with Australian Standard AS 2278.1. The current version, AS 2278.1-2008 requires that: • Aerosol dispensers shall include the applicable warnings and markings, directions for use, and any additional operating precautions that alert consumers to the specific dangers of the product.
Spray April 2015
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