Regulatory Helpdesk: March 12

Combustible Liquids, Using Chemtrec’s Number, Keeping Up-To-Date, and Other Paperwork

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.

DG Documentation on Overpacks

Q. If there are multiple skids of dangerous goods (overpacks) in a shipment on which one should the copies of the invoices and shipping papers be attached?
A. Neither the DOT nor IATA regulations tell you to put “paperwork” on the outer packages or overpacks. That is a carrier/driver thing. All the regulations care about is the proper marking and labeling that they require. You also have to be able to physically hand your paperwork to the carrier. Your best bet would be to talk to your carrier directly as to how they want it handled.

Combustible Liquids

Q. I have a liquid with a flashpoint of 100° F and it does not meet any other hazard classes. It is not an RQ, waste or marine pollutant. After manufacturing, it is placed in tubes and then shipped for sale in retail stores. What marks and labels are needed on the outside of the packages?
A. The flashpoint of this material is 100° F and there are no other hazards under the transport regulations. This means it technically meets the definition of a flammable liquid in Packing Group III per §173.120 and §173.121. Since these are packaged in small containers designated for retail sale and consumer use, they would be regulated as ORM-D Consumer Commodities.

However, §173.150(f)(1) for exceptions for class 3 allows a flammable liquid with a flash point at or above 38C (100° F) that does not meet definition of any other hazard class to be RECLASSED as a combustible liquid. Combustible liquids are only regulated as hazardous materials under DOT when they are in bulk packages. Bulk packages hold over 119 gallons or 882 pounds. Your tubes are neither bulk packages nor boxes into which they are placed for transport. This means even though your tubes hold a combustible liquid the container size is such that it is not regulated.

Chemtrec’s Number

Q. Can I use Chemtrec’s or a similar 3rd party number as the information number on lithium battery mark labels?
A. That depends on your contract. Although “CANUTEC”, as a government agency is limited in the service that they provide (i.e., emergency information only, on shipping documents), private industry associations on a fee-for-service basis may have provision to respond to requests for non-emergency shipment information as contemplated for the number required on the package.

Keeping Up-to-Date with the Regulations

Q. How do I know what changes have happened in DG/HMT regulations since my last course?
A.You could check the appropriate website periodically, but the simplest way to keep updated is to sign up for update bulletins – for example ICC’s Compliance Bulletin – which will tend to provide information across the range of regulations. [Editor’s Note: You can sign up for Compliance Bulletin below, or by clicking here.]

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