The Challenge of Two-Day
Shipping for Aerosols
Over the last several decades, technology has developed
by leaps and bounds. German physicist Heinrich Hertz
first produced radio waves in 1886, which paved the
road for today’s cell phones. In 1936, Alan Turing proposed the
Turing machine, which became the foundation for theories about
computing and computers. In 1980, Vinton Cerf and Bob Kahn
created a set of guidelines for data transfer using packet switching,
which laid the foundation for the internet. I highly doubt that
these men realized at the time that their work would revolutionize
the way consumers shop. None of these men could have foreseen
that their work would give us the ability to buy anything with the
tap of the finger and have that product arrive on our doorstep
without delay in two days, one day or even the same day. I’m sure
those of you who had last-minute gifts delivered on Christmas
Eve know what I mean.
However, nearly instantaneous delivery, which has
become an expectation associated with e-commerce, means
that goods must more often travel by air. This presents a
unique set of regulatory and logistical challenges for aerosol
products—a set of challenges that does not burden similar
products that are delivered to retail locations via ground
Although the differences of aerosol shipping methods
can make your head spin, not properly shipping aerosol
products by air can lead to some stiff penalties. Between
2013 and 2015, there were six Federal Aviation Administration
(FAA) enforcement cases involving improperly shipped
aerosol products by air. Those six cases had a total of $414,020 in
proposed penalties, so following the proper regulations is critical.
Below is a quick overview of some of the complexities of aerosol
air transport, and how HCPA is working to harmonize U.S. and
global regulations, while ensuring that safety is at least maintained,
if not improved.
Products and materials that meet the criteria of one of the nine
hazard classes are regulated as hazardous materials when offered
for transportation. Aerosol products, due to their pressure, are
Class 2, typically Division 2.1 or 2.2 depending on the following
• If the contents of the aerosol product include 85% by
mass or more flammable components and the chemical
heat of combustion (HOC) is 30 kJ/g or more, it must be
assigned to Division 2.1.
• If the contents of the aerosol product contain 1% by mass
or less flammable components and the HOC is less than 20
kJ/g, it must be assigned to Division 2.2.
• For any aerosol product not meeting either of the above
two bullets, the product must be classed in accordance with
the appropriate tests of the United Nations (UN) Manual of
Tests & Criteria.
• Flammable components are Class 3 flammable liquids,
Division 4.1 flammable solids, or Division 2.1 flammable
gases. The chemical HOC must be determined in accordance
with the UN Manual of Tests & Criteria.
While the U.S. Dept. of Transportation (DOT) allows an
exception that reduces the regulatory burden of shipping limited
quantities of aerosol products (must be under 30 kg 66 lbs and
comply with 49 CFR § 173.306), there are still differences between
ground and air requirements that complicate air transport.
Below, find the limited quantity marking for both ground
transportation and air transportation.
Limited Quantity Marking
Additionally, the following are general requirements when shipping
aerosols via air under the limited quantity exemption in the
U.S. that don’t apply to ground shipments:
• Shipping papers with emergency response information must
• The UN number and proper shipping name must be
• Proper hazard class marking(s) must be used.
Beyond these domestic differences, since U.S. regulations and
definitions for aerosols often differ from the rest of the world, this
further complicates international air transport.
For example, aerosol products that fall under Division 6.1 are
prohibited from air transport in the U.S., but are allowed internationally,
provided certain criteria are met.
The container size can also make a difference. For the air
transport of limited quantities of non-flammable plastic aerosol
products that do not have hazard concerns other than pressure,
10 Spray February 2019
Director, Scientific Affairs, HCPA
Are complicated air transport rules holding back aerosols in the online marketplace?
For Ground Transportation For Air Transportation
Continued on page 38