The question came to me on April 25, 2018:
Hi,
I found your website when researching hazmat and transportation rules for alcohol wipes and saw your article about them not being subject to Hazardous Material Regulations of PHMSA/USDOT as long as there is no loose liquid in the packet.
The question I have is with regards to the SDS for this kind of item; how would it look and what transportation and packing class would it be under?
Any help would be greatly appreciated.
Thanks,
My reply was a few days later on May 1, 2018:
I am terribly sorry for my delay. Please see below.
- You are correct that under certain specified conditions an alcohol wipe is not subject to the Hazardous Materials Regulations of the USDOT/PHMSA.
- Therefore, it has no requirements under the HMR for its transportation. It has no “packing class” (I believe you mean either the hazard class or packing group) because it is not subject to USDOT/PHMSA regulations for its transportation.
- In section 14 of the SDS you may indicate that it is not subject to USDOT/PHMSA Hazardous Materials Regulations as packaged due to special provision 47.
I hope this helps. I apologize again for my delay.
Please contact me with any other questions.
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That seemed to do it!
You might be wondering, “What in the world is section 14 of the SDS? And just what is special provision 47?” Section 14 – Transportation information is the section of the SDS detailing the transportation requirements (domestic and international) for the hazardous chemical described on the SDS. Unfortunately, it – along with Section 12 – Ecological information, Section 13 – Disposal information, and Section 15 – Regulatory information are required to be in the SDS (to be consistent with the UN Globally Harmonized System of Classification and Labeling of Chemicals) but their content will not be enforced by the Occupational Health and Safety Administration (OSHA) or any other regulatory agency in the U.S. So don’t rely on what you read in Sections 12 through 15 of the Safety Data Sheet.
Read more about the sixteen sections of the safety data sheet
Special Provision 47, found in column 7 of the Hazardous Materials Table for the entry: UN3175, Solids containing flammable liquid, n.o.s. 4.1, PG II, is explained in 49 CFR 172.102 of the HMR. It reads in part:
Small inner packagings consisting of sealed packets and articles containing less than 10 mL of a Class 3 liquid in Packing Group II or II absorbed onto a solid material are not subject to this subchapter provided there is no free liquid in the packet or article.
So, what does special provision 47 mean? Alcohol wipes in sealed packets are not subject to USDOT/PHMSA transportation regulations as long as there are no free liquids in the packet.
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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 |