How to determine if a product is regulated, SAPT on a SDS, Shipping a done, and using a UN package
Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. We’re here to help you become independent with – and understand the whys and hows – of the regulations.
Is my product regulated?
- Q. I have 2 products I distribute to various stores to sell. The SDS files say my product is not regulated under DOT and TDG in Section 14. Since this is sold as a consumer product, doesn’t that mean it is regulated for IATA should I ship it via air? (the SDS were emailed to me)
- A. Nothing in your SDS files leads me to believe either one would meet any of the 9 hazard classes in IATA. This is further confirmed by neither SDS classifying the products for DOT and TDG. Basically, what you have are containers of non-regulated liquids. There is no need for UN Specification packaging or paperwork for IATA or any other transport regulation.
SAPT on my SDS
- A. Since the addition of UN numbers for polymerizing substances, we’ve been told we must include the Self-Accelerated Polymerization Temperature (SAPT) on our SDS documents in Section 9. Is this a new requirement?
- Q. There is no requirement in OSHA HazCom 2012 to include that particular data point in Section 9. All of the required elements for Section 9 of an SDS can be found in Appendix D to the OSHA HazCom 2012 standard.
- Q. Our company uses lithium battery powered drones to survey certain land areas. One of them crashed recently and we need to send it for repair. The battery is still inside the drone. Do I need training to do this? What are my options if I am not trained?
- A. In this case, yes you will need training since the lithium battery inside the drone qualifies as a dangerous good. If you do not have training, then the other options would be to use a repacking company or a freight forwarder.
ICC can help with repacking shipments like this. Learn more about Repacking with ICC.
Using a UN Package
- Q. In my warehouse I have quart can F style containers available for use. Can I use your quart F style shipper UN box with my F style quart cans with closure if I purchase your boxes?
- A. It depends on the specifics of the quart can you plan to use. Per the 49 CFR §178.601 (1), variations of the inner packaging are allowed if they maintain an equivalent level of performance. The F style quart can must be of similar design, must be of equal size of the original tested inner container or smaller and have the same or smaller openings. In addition, the closure must maintain at least an equivalent level of performance per 178.601 (1) (i).