49 CFR 173.173 contains the packing instructions for paint, paint-related material, adhesives, ink, and resins.  If you intend to offer for transportation, i.e. ship, or transport in commerce any of the above – either as a product or a waste – you must be familiar with the packing instructions of §173.173 and the exception from some of the Hazardous Material Regulations it offers.

First of all, in order for your shipment to be subject to this section, it must be referred to by the Hazardous Materials Table at §172.101.  Confirming this is a three-step process:

1. Identify the proper shipping name in column 2 of the Table.
2. Determine the packing group for the HazMat.
3. Look to column 8(B) of the Table for the applicable section of Part 173 and its packing instructions. e.g. “173” in column 8(B) refers a shipper to 49 CFR 173.173.

Currently, only the hazardous materials identified in Table 1 of this article (below) are subject to the packing instructions of §173.173 and are the only hazardous materials that can be packaged according to this Section.

Table 1:

Hazardous Materials referred to 49 CFR 173.173 in column 8(B) of the Hazardous Materials Table
Proper Shipping Name	Packing Group
Adhesives, containing a flammable liquid	II & III
Paint including paint, lacquer, enamel, stain, shellac solutions, varnish, polish, liquid filler, and liquid lacquer base	II & III
Paint or Paint related material	II & III
Paint related material including paint thinning, drying, removing, or reducing compound	II & III
Printing ink, flammable or Printing ink related material (including printing ink thinning or reducing compound), flammable	I, II, & III
Resin solution, flammable	II & III

Note that except for Printing ink, flammable or Printing ink related material; no packing group I HazMat is eligible to be packaged according to the requirements of this Section.

There will be more on Printing ink, flammable or Printing ink related material later in this article.

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HazMat packaged according to the requirements of this Section are subject to the following requirements:

• Except as otherwise provided in this Part (i.e. unless contradicted by other regulations in 49 CFR Part 173) or unless a more specific proper shipping name is available, the proper shipping name of “Paint” must be used for the following materials:
  • paint
  • lacquer
  • enamel
  • stain
  • shellac
  • varnish
    

    The placard and ID# for Paint or Paint Related Material

  • liquid aluminum
  • liquid bronze
  • liquid gold
  • liquid wood filler
  • liquid lacquer base
• The proper shipping name of “Paint-related material” must be used for paint thinning, drying, reducing or removing compound unless a more specific proper shipping name is listed in the Hazardous Materials Table.

Beyond the proper shipping name, all HazMat subject to this section must be packaged by one of three methods:

1.  Eligible HazMat of packing group II must be packaged according to the requirements of §173.202 – Non-bulk packagings for liquid hazardous materials in Packing Group II, which requires:

• Non-bulk packaging only.
• General packing requirements of subpart B of part 173 apply.
• Use only the authorized packagings (combination and single) listed.
• Specification packaging required.

2.  Eligible HazMat of packing group III must be packaged according to the requirements of §173.203 – Non-bulk packagings for liquid hazardous materials in Packing Group III, which requires:

• Non-bulk packaging only.
• General packing requirements of subpart B of part 173 apply.
• Use only the authorized packagings (combination and single) listed.
• Specification packaging required.

Or…

3.  A packaging exception found only in 49 CFR 173.173(b)(2), which requires:

• A combination packaging.
• Inner glass packaging of ≤1 L (0.3 gallon) capacity or inner metal packaging of ≤5 L (1 gallon).
• Packed in strong outer packaging.
• The general packing requirements of subpart B of part 173 apply.
• But – and this is the big one:  specification packaging is not required.

The big deal about the packaging exception of §173.173(b)(2) is that as long as the volume restrictions are met – along with some simple packaging requirements – specification packaging is not required.  Note that all other requirements of the HMR remain; those such as: HazMat labels, shipping papers with the shipper’s certification, markings, placards, HazMat securement and segregation, and HazMat Employee training.

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Question:

What packaging options do I have if I offer for transportation a Printing ink, flammable or Printing ink related material (UN1210), packing group I?

Answer:

Strange as it seems, there are only three options for packaging a Printing ink, flammable or Printing ink related material, packing group I; they are:

1. As a limited quantity per the requirements of 49 CFR 173.150.  A limited quantity can only be a non-bulk combination packaging and must have a gross package weight of ≤33 kg.
2. Per the requirements of 49 CFR 173.243 if in a bulk packaging.
3. As described in 49 CFR 173.173(b)(2) if a non-bulk packaging.  The packaging options of §173.202 and §173.203 are not available since they only apply to HazMat in packing group II or III respectively.

Shipping paint?  Interested in the packing instructions that may apply?  And the exception that may be available?  Contact me if you have any questions not answered by this article or if you require training for your HazMat Employees.