REMINGTON HAZARDOUS MATERIALS TRANSPORT DATA SHEET
COMMODITY: RemOil® Wipes, with or without MoistureGuard;
in pop-up style inner packages up to 1 kg (2.2 pounds) net capacity each, in outer packages up to 30 kg (66 pounds) gross.
MODE OF TRANSPORTATION: Domestic Road and Rail
|PROPER SHIPPING NAME:||Solids containing flammable liquid, n.o.s. (petroleum distillates)||LABEL:||No|
|IDENTIFICATION NUMBER:||UN 3175||PLACARD:||No|
|HAZARD CLASS/DIVISION:||4.1||EMERG. INFO:||No|
|(1)Sym-bols||(2)Hazardous materials descriptions and proper shipping names||(3)Hazard class or Division||(4)Identifi-cation Numbers||(5)PG||(6)Label Codes||(7)Special provisions(§172.102)||(8)Packaging (§173.***)||(9)Quantity Limitations(see §§173.27 and 175.75)||(10)Vesselstowage|
|Bulk||Passenger aircraft/ rail||Cargo aircraft only||Loca-|
|G||Solids containing flammable liquid, n.o.s.||4.1||UN3175||II||3||47, IB6, IP2, T3, TP33||151||212||240||15 kg||50 kg||B|
RemOil Wipes in pop-up containers may be classed as Division 4.1 without testing, but remain dangerous goods, per the Special Provision 47:
SP47: Mixtures of solids that are not subject to this subchapter and flammable liquids may be transported under this entry without first applying the classification criteria of Division 4.1, provided there is no free liquid visible at the time the material is loaded or at the time the packaging or transport unit is closed. Except when the liquids are fully absorbed in solid material contained in sealed bags, for single packagings, each packaging must correspond to a design type that has passed a leakproofness test at the Packing Group II level. Small inner packagings consisting of sealed packets and articles containing less than 10 mL of a Class 3 liquid in Packing Group II or III absorbed onto a solid material are not subject to this subchapter provided there is no free liquid in the packet or article.
Citation: 49 CFR 173.151
RemOil Wipes classed as Division 4.1 flammable solids may be transported as limited quantities when packaged as follows:
- Packed in inner packages inside an outer package (a combination package)
- Must be packed upright, packed to prevent shifting, in securely-closed strong outside packagings; no specification testing is required.
- The inner packages are limited to 1 kg (2.2 pounds) net each, and the maximum gross weight of the outer package is limited to 30 kg (66 pounds). There is no limit on the number of packages in a shipment.
Citation: 49 CFR 173.151
SHIPPING PAPER REQUIREMENTS
Normal documentation requirements are waived when transported by road. RemOil Wipes are still hazmat, but are not marked “HM” on the shipping document because they are not subject to documentation requirements. ORM-D or LQ should not be listed to allow mixed shipments of ORM-D and LQ packages; only “Flammable solid” should be listed, and even that is not mandatory.
|RemOil wipes, flammable solid (?)||(Insert gross or net weight)|
Citation: 49 CFR 173.151
Limited quantity packages containing RemOil Wipes must display the limited quantity marking on one side.
In addition, each carton may have to be marked with the consignor’s or the consignee’s name and address, see 49 CFR §172.301(d) for exceptions. No UN number or proper shipping name is required.
* Per 49 CFR §172.301(d), the package must be marked with the consignor or consignee’s name and address unless the package is:
(1) Transported by highway only and will not be transferred from one carrier to the other;
(2) Part of a carload lot, truckload lot or freight container load, and the entire contents of the rail car, truck or freight container are shipped from one consignor to one consignee.
Citation: 49 CFR §172.301(d), §172.312, §172.315 (a) & 49 CFR §173.150
The “OVERPACK” marking is only required if the limited quantity marking is not visible, in which case the “Limited Quantity” and “overpack” stickers are required on only one side of the pallet or overpack box.
Remington policy is to apply the overpack and LQ stickers to all pallets, regardless of visibility of product underneath. The Overpack sticker can be replaced by a sheet of paper or label that says “OVERPACK” in 1/2″ letters or bigger, e.g. on a paper list of goods applied to the overpack.
Citation: 49 CFR §173.25
POSSIBILITY FOR EXCEPTION FROM REGULATION BY US GROUND
RemOil® is a mixture of flammable liquid petroleum distillates with a flash point of 105 oF, with or without MoistureGuard. Per 49 CFR 173.121, this is a Packing Group III flammable liquid (73 – 140 oF). The PG III entry for Flammable liquids, n.o.s. in the hazardous materials table (172.101) indicates that packaging exceptions may be used in 173.150. In the USA, a special hazard class called combustible liquids exists. Flammable liquids with a flash point 140 – 200 oF may be reclassified as combustible liquids. A special case exists for flash point ≥ 100oF to be combustible liquid only for road and rail (except in Alaska or similar places that must use air and vessel), per 173.150(f)(1). The requirements of the sub-chapter (the hazardous materials regulations) do not apply to a combustible liquid in a non-bulk packaging except for hazardous substances, hazardous wastes or marine pollutants, per 173.150(f)(2). These do not normally apply to RemOil®, which is not a marine pollutant per Appendix B of 172.101. Therefore RemOil® is not regulated as a hazardous material for road or rail transport in the USA. The same applies for RemOil Wipes.
Remington’s company policy is for RemOil Wipes to be shipped as LQ for surface shipments globally, and fully regulated by air. This eliminates possibilities for non-compliance when shipping by vessel or exporting. There should be no difference in transportation cost between shipments of LQ or non-regulated products.
Wipes in packets are not regulated.
Citation: 49 CFR references: 172.101, 173.120(b), 173.121(f), 173.150