Whether shipping a hazardous material or dangerous good by highway, air, rail or vessel; whether transported internationally or within the U.S.; the shipper of a hazardous material is responsible for its classification. This includes – among other things – determining the applicable hazard class – or division – and the packing group, if it has one. This is a requirement of all three regulatory agencies that regulate the transportation in commerce of hazardous materials/dangerous goods:
- The Pipeline and Hazardous Materials Safety Administration (PHMSA) within the U.S. Department of Transportation (USDOT).
- The International Air Transport Association (IATA) whose regulations are based on those of the International Civil Aviation Administration (ICAO).
- The International Maritime Organization (IMO).
The purpose of this article is to provide the regulatory standard for determining the packing group of a Class 8 Corrosive.
The good news is that all three regulatory agencies for the transport of hazardous materials use the same criteria for the classification of a Class 8 Corrosive. This includes the determination of its packing group. Unlike IATA and the IMO, however, PHMSA does not tabulate its data and instead requires the reader to find their way through some confusing text. The table below can be seen in almost exactly this form in the regulations of IATA and the IMO and neatly clarifies those of PHMSA.
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| Packing Group | Exposure Time | Observation Time | Effect |
|---|---|---|---|
| I - Greatest Danger | Up to but no more than 3 minutes | Up to but no more than 60 minutes | Full thickness destruction of intact skin |
| II - Moderate Danger | More than 3 minutes and up to but no more than 60 minutes | Up to but no more than 14 days | Full thickness destruction of intact skin |
| III - Lowest Danger | More than 60 minutes and up to but no more than 4 hours | Up to but no more than 14 days | Full thickness destruction of intact skin |
| III - Lowest Danger | N/A | N/A | Corrosion rate on steel or aluminum more than 6.25 mm/year at test temperature of 55 degrees Celsius |
Remember: there are eight other hazard classes, some of them with their own criteria for determining the packing group. Make certain you consider each of them and a lot more when you classify your HazMat/dangerous good prior to offering it for transportation.
Please don’t hesitate to contact me if you require any assistance in the classification of your hazardous material.
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Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail International and Domestic Daniels Training Services, Inc. 815.821.1550 |