Normal documentation requirements are waived when transported by road. This aerosol is still hazmat, but it is not marked “HM” on the shipping document because it is not subject to documentation requirements. ORM-D or LQ may but should not be listed to allow mixed shipment of ORM-D and LQ packages; only “Aerosols” should be listed, and even that is not mandatory.
Limited quantity packages containing aerosols must display the following limited quantity marking on one side as
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.
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 HAZARDOUS MATERIALS TRANSPORT DATA SHEET
COMMODITY: RemOil® Wipes, with or without MoistureGuard; in pop-up style inner packages up to 5 kg (11 pounds) net capacity each, in outer packages up to 30 kg (66 pounds) gross.
MODE OF TRANSPORTATION: Domestic & International Vessel
(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
Excep-tions
Non- bulk
Bulk
Passenger aircraft/ rail
Cargo aircraft only
Loca- tion
Other
(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8A)
(8)
(8C)
(9A)
(9B)
(10A)
(10B)
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
CLASSIFICATION
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.
This is also true in the IMDG, Special Provision 216:
SP216: Mixtures of solids which are not subject to the provisions of this Code and flammable liquids may be transported under this entry without first applying the classification criteria of class 4.1, provided there is no free liquid visible at the time the substance is loaded or at the time the packaging or cargo transport unit is closed. Each cargo transport unit shall be leakproof when used as a bulk container. Sealed packets and articles containing less than 10 mL of a packing group II or III flammable liquid absorbed into a solid material are not subject to the provisions of this Code provided there is no free liquid in the packet or article.
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.
This is the only difference between LQ Ground and Vessel – documentation is required. The difference in the document between LQ and not LQ is the addition of “LTD QTY” at the end of the description.
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.
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.
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.
(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
Excep-tions
Non- bulk
Bulk
Passenger aircraft/ rail
Cargo aircraft only
Loca- tion
Other
(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8A)
(8)
(8C)
(9A)
(9B)
(10A)
(10B)
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
CLASSIFICATION
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.
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.
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.
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.
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.
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.
REMINGTON HAZARDOUS MATERIALS TRANSPORT DATA SHEET
COMMODITY: Wipes containing RemOil® with or without MoistureGuard; Brite Bore, 40-X Bore Cleaner; when packaged in packets are not regulated as hazmat / dangerous goods anywhere, by any mode.
MODE OF TRANSPORTATION: All
NOTE: Hazardous flammable liquids absorbed in non-hazardous solids are regulated as hazardous materials, with certain exceptions. Wipes not regulated when there is 10mL maximum of flammable liquid, other than Packing Group I, and the wipe is packaged in a sealed packet. The regulatory path from UN 3175 to be exempted from the regulations is described below.
OVERVIEW – this shows the fully regulated version.
(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
Excep-tions
Non- bulk
Bulk
Passenger aircraft/ rail
Cargo aircraft only
Loca- tion
Other
(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8A)
(8)
(8C)
(9A)
(9B)
(10A)
(10B)
Solids containing flammable liquid, n.o.s.
3
UN3175
II
4.1
47, IB6, IP2, T3, TP33
151
212
240
15 kg
50 kg
B
BASIS OF THE REGULATORY EXCEPTION
Wipes containing RemOil or other flammable liquids, are not regulated when meeting certain criteria, per similar special provisions of the USA, and international ocean and air transport regulations. The criteria are:
First, there can be no free liquid at the time of filling to be classed into UN 3175, unless flammable solid testing is done.
To then exit the regulations:
Package in a sealed packet
Have no more than 10 mL of liquid absorbed
Liquid must be PG II or III (not PG I)
Have no free liquid
RemOil packets qualify, as they are sealed, contain less than 10 mL of RemOil, RemOil and other Remington cleaners are PG II or less, and the wipes have no free liquid. The special provisions are shown below for the USA, IMDG and ICAO TI.
SPECIAL PROVISION 47 – USA
“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.”
SPECIAL PROVISION 216 – INTERNATIONAL MARITIME REGULATIONS
“Mixtures of solids which are not subject to the provisions of this Code and flammable liquids may be transported under this entry without first applying the classification criteria of class 4.1, provided there is no free liquid visible at the time the substance is loaded or at the time the packaging or cargo transport unit is closed. Each cargo transport unit shall be leakproof when used as a bulk container. Sealed packets and articles containing less than 10 mL of a packing group II or III flammable liquid absorbed into a solid material are not subject to the provisions of this Code provided there is no free liquid in the packet or article.”
SPECIAL PROVISION A46 – INTERNATIONAL MARITIME REGULATIONS
Mixtures of solids which are not subject to these Instructions and flammable liquids may be transported under this entry without first applying the classification criteria of Division 4.1, providing there is no free liquid visible at the time the substance is packaged and, for single packagings, the packaging must pass a leakproofness test at the Packing Group II level. Small inner packagings consisting of sealed packets or articles containing less than 10 mL of a Packing Group II or III flammable liquid absorbed into a solid material are not subject to these Instructions provided there is no free liquid in the packet or articles.
SOME OTHER EXCEPTIONS
Depending on the flash point, RemOil® and other flammable liquids may be partially or fully excepted as combustible liquids from the hazardous materials regulations, and in some cases international regulations. Some specifics are given in the relevant transport data sheet. These exceptions are not needed when the flammable liquids are incorporated into wipes, meeting certain criteria. In case of a full exception, then the criteria above are not necessary. RemOil, with a flashpoint of 105F, does not qualify for a full exception except in wipes.
REMINGTON HAZARDOUS MATERIALS TRANSPORT DATA SHEET
COMMODITY: RemOil®, with or without MoistureGuard; in liquid form, in outer packages up to 60 L (15.8 gallons).
MODE OF TRANSPORTATION: International Air
OVERVIEW
PROPER SHIPPING NAME:
Flammable liquid, n.o.s. (petroleum distillates)
LABEL:
Yes
IDENTIFICATION NUMBER:
UN 1993
PLACARD:
N/A
HAZARD CLASS/DIVISION:
3
EMERG. INFO:
Yes
PACKING GROUP:
III
TRAINING:
Required
DOCUMENT:
Yes
PACKAGING:
Spec
MARKING:
Yes
DANGEROUS GOODS LIST
CLASSIFICATION
RemOil has a flashpoint of 105F, and therefore it is a PG III flammable liquid. It is comprised of petroleum distillates and petroleum oil. These are both dangerous goods, and in pure forms would be shipped as UN 1268 Petroleum Distillates, N.O.S. and UN 1268 Petroleum Products, N.O.S.
It is shipped as UN 1993 with the proper shipping name “Flammable liquid, n.o.s. (petroleum distillates)”. The abbreviation n.o.s. means “not otherwise specified”. N.O.S. entries are used when a specific proper shipping name does not exist, or the product is a mixture. Since petroleum distillates are the primary component, they are used for the technical name in parentheses.
Citations: IATA Chapter 3.2; Dangerous Goods List
LIMITED QUANTITIES
RemOil liquid is eligible for LQ-Air up to 1oL per shipping case. However Remington’s policy is to mark packages of RemOil as LQ for surface. Therefore the LQ-Y mark should never be used.Unlike other modes where LQ has significant cost savings, the only exception by air is from package testing; there is no exception from shipping papers or labeling.
Many airlines have filed variations prohibiting LQ shipments, which would necessitate labor to obliterate the Y-mark. There is an example in the IATA DGR that the LQ surface mark may remain on the package and be ignored in international air. This eliminates the labor to remove it, and allows the package to be LQ during the international journey on the surface leg subsequent to air transport.
Citations: IATA 2.8.3.5 (operator restrictions); Dangerous Goods List Columns G & H (LQ is forbidden); 7.1.5.5 and Figure 7.2.A (the ground LQ mark is allowed and ignored)
PACKAGING INFORMATION
RemOil is classified as UN 1993, PG III, and therefore must be packed according to Packing Instruction 355:
The package must be tested, and bear the specification package mark, for example:
The maximum gross weight is typically 400 kg (882 pounds) per package (bearing in mind the maximum net capacity is 60 L for passenger aircraft or 220 L for cargo-aircraft-only).
The outer packaging codes are specifications with minimum standards of construction and maximum gross weights.
International air transport is subject to the requirements of IATA, the International Air Transport Association. A special document is required called a Dangerous Goods Declaration (DGD) in addition to any standard bill of lading. Fill out the DGD as follows in four sequences:
Sequence 1 – Dangerous Goods Identification
The sequence is: “UN 1993, Flammable liquid, n.o.s. (petroleum distillates), 3, PG III”.
For different UN numbers each change to Sequence 1 must be on a new line. For different bottle sizes of the same Sequence 1 information, Sequence 1 can be done once and associated with more than one line in Sequence 2 (read below).
Sequence 2 – Quantity and Type of Packing
The sequence is “QUANTITY PACKAGING:MATERIAL-TYPE X NET-QUANTITY”, e.g. “5 fibreboard boxes X 4.5 kg”. Quantity is the number of shipping cases (packages). The degree of rounding is not specified, but may be to the nearest kilogram, and should be consistent between the DGD, package and overpack markings. Packaging type is denoted by material and type, e.g. “fibreboard boxes” or “steel drums”. Metric units must be used, which for liquids is “L” for liters, upper case; metric units are case sensitive, e.g. kg is lower case.
For multiple products, each change to Sequence 2 must be on a different line, e.g. different net weight, but Sequence 1 does not have to be repeated if together. See IATA DGR Figure 8.1.K.
When overpacks are used:
Packaging in overpacks must be listed first.
The wording “Overpack Used” must be inserted on the declaration form immediately after all the entries in the overpack.
When a consignment consists of multiple overpacks each overpack must have an identification marking any alpha-numeric format) and be marked with the total quantity of dangerous goods within the overpack including the unit of measurement.
The total quantity(ies) shown on the Shipper’s Declaration must match the total quantity(ies) shown on the overpack.
Multiple overpacks with identical contents must be identified as follows: “Overpack Used X (number of identical overpacks)”, (see IATA Figure 8.1.L and Figure 8.1.N, examples 8 and 10). Multiple overpacks with different contents must be identified by listing them separately
Sequence 3 –Packing Instruction
Write the number of the applicable packing instruction, “355”.
Sequence 4 – Authorizations
Use this to describe any government authorizations, e.g. EX numbers for explosives. This column is likely not applicable to RemOil, and may be left blank.
The following example is for a pallet of RemOil 2-oz bottles, and a second pallet with both 2-oz and RemOil and ammunition. The dashed red line is put there to distinguish the two different pallets, and is not part of the document. For more information, see IATA Figure 8.1.N on shipping liquids and solids on the same pallet.
Citation: IATA 8.1.6.9
CARTON MARKING & LABELING
Upper case letters are not required, but are better than lower case to meet the text size requirements uniformly. Packages containing small arms ammunition must display the following markings and at least 6mm (1/4”) high, or an appropriate size for packages which are ≤5 kg net, as follows:
Proper shipping name – “FLAMMABLE LIQUID, N.O.S. (PETROLEUM DISTILLATES)”
UN# – “UN 0012”
the full name and address of the shipper and the consignee, located on the same package surtace and near the proper shipping name, if the package dimensions are adequate;
per IATA requirements, the net quantity, in liters, abbreviated “L” in upper case, e.g. “0.34 L”. The “L” has to be in upper case per the specifications of the metric system (“kg” has to be lower case). The net quantity must be marked adjacent to the UN number and proper shipping name. It may be rounded to the nearest liter, or to a desired level of decimals for better accuracy and alignment with the overpack weight. The net quantity should be identical to that shown on the Dangerous Goods Declaration document.
the specification package marking, placed in a location and of such size relative to the package as to be readily visible. Must be pre-printed or affixed, and not handwritten. For packages with a gross weight exceeding 30 kg the marking, or a duplicate thereof, must appear on the top or on the side of the package. For example:
The Class 3 hazard label must be applied as follows:
When the package dimensions are adequate, labels must be located on the same surface of the package near the proper shipping name marking.
Labels should be affixed adjacent to the shipper’s or consignee’s address appearing on the package.
Unless the package dimensions are inadequate, the label(s) must be affixed at an angle of 45 degrees (diamond shaped) to the surrounding markings.
The surface LQ mark is not valid in international air transport, but may remain on the package and be ignored in air transport, and be valid for further surface transport when the air journey is over. See IATA 7.1.5.5 and IATA Figure 7.2.A.
Citation: IATA 6.0.4.1, 7.1.4, 7.1.5, 7.2.6.2
OVERPACK MARKINGS
Examples of overpacks include pallets and specification packages placed in another packaging. International air transport is subject to the requirements of IATA, the International Air Transport Association, which requires unique pallet markings.
Unless all markings and labels representative of all dangerous goods in the overpack are clearly visible, the overpack must be marked with:
the word “OVERPACK” in letters at least 12 mm (1/2”) high;
UN number
proper shipping name
full names and addresses of the consignor and consignee
The following requirements apply even if all markings are visible:
If there is more than one UN number in an overpack, write each UN number and the total quantity of dangerous goods for each UN number.
If there are two or more overpacks, name and mark each pallet with a unique identification mark (which may be in any alpha-numeric format) and the total quantity of dangerous goods, as indicated on the Dangerous Goods Declaration.
Normally we would use this OVERPACK sticker for domestic shipments:
However since there is so much information required, we print it on a piece of paper instead, with OVERPACK and the UN number in 1/2″ print, and affix it to the pallet. Following are two examples corresponding to the example shippers declaration above, one for RemOil alone on a pallet, and another for both RemOil and ammo on the same pallet:
REMINGTON HAZARDOUS MATERIALS TRANSPORT DATA SHEET
COMMODITY: RemOil®, with or without MoistureGuard; in liquid form, in inner packages up to 1.3 gallons, in outer packages up to 30 kg gross.
MODE OF TRANSPORTATION: Domestic & International Vessel
OVERVIEW
PROPER SHIPPING NAME:
Flammable liquid, n.o.s. (petroleum distillates)
LABEL:
No
IDENTIFICATION NUMBER:
UN 1993
PLACARD:
No
HAZARD CLASS/DIVISION:
3
EMERG. INFO:
No
PACKING GROUP:
III
TRAINING:
Required
DOCUMENT:
Yes
PACKAGING:
Non-spec
MARKING:
LQ Mark
HAZMAT TABLE
(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
Excep-tions
Non- bulk
Bulk
Passenger aircraft/ rail
Cargo aircraft only
Loca- tion
Other
(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8A)
(8)
(8C)
(9A)
(9B)
(10A)
(10B)
G
Flammable liquid, n.o.s.
3
UN1993
III
3
B1, B52, IB3, T4, TP1, TP29
150
203
242
60L
220L
A
PACKAGING INFORMATION
RemOil is classed as Class 3 flammable liquids and 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 1.3 gallons capacity, 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.
This is the only difference between LQ Ground and Vessel – documentation is required. The difference in the document between LQ and not LQ is the addition of “LTD QTY” at the end of the description.
Limited quantity packages containing RemOil must display the limited quantity marking on one side.
The liquid orientation arrows must be present on two opposite sides of the package. This is not required for small inner packages, but Remington marks all packages with this mark to avoid mistakes when switching modes or when breaking cases. The thresholds for the mark are 1 liter for domestic ground, and 120 mL (4 oz) for air.
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.
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.
Liquid orientation arrows must be placed on two opposite sides of the overpack, even if they can be seen through the stretch wrap.
Remington policy is to apply the overpack, LQ and liquid 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.
REMINGTON HAZARDOUS MATERIALS TRANSPORT DATA SHEET
COMMODITY: RemOil®, with or without MoistureGuard; in liquid form, in inner packages up to 1.3 gallons, in outer packages up to 30 kg gross.
MODE OF TRANSPORTATION: Domestic Road and Rail
OVERVIEW
PROPER SHIPPING NAME:
Flammable liquid, n.o.s. (petroleum distillates)
LABEL:
No
IDENTIFICATION NUMBER:
UN 1993
PLACARD:
No
HAZARD CLASS/DIVISION:
3
EMERG. INFO:
No
PACKING GROUP:
III
TRAINING:
Required
DOCUMENT:
No
PACKAGING:
Non-spec
MARKING:
LQ Mark
HAZMAT TABLE
(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
Excep-tions
Non- bulk
Bulk
Passenger aircraft/ rail
Cargo aircraft only
Loca- tion
Other
(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8A)
(8)
(8C)
(9A)
(9B)
(10A)
(10B)
G
Flammable liquid, n.o.s.
3
UN1993
III
3
B1, B52, IB3, T4, TP1, TP29
150
203
242
60L
220L
A
PACKAGING INFORMATION
RemOil is classed as Class 3 flammable liquids and 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 1.3 gallons capacity, 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.
Normal documentation requirements are waived when transported by road. RemOil is still hazmat, but it is not marked “HM” on the shipping document because it is not subject to documentation requirements. ORM-D or LQ may but should not be listed to allow mixed shipment of ORM-D and LQ packages; only “Flammable liquid” should be listed, and even that is not mandatory.
Limited quantity packages containing RemOil must display the limited quantity marking on one side.
The liquid orientation arrows must be present on two opposite sides of the package. This is not required for small inner packages, but Remington marks all packages with this mark to avoid mistakes when switching modes or when breaking cases. The thresholds for the mark are 1 liter for domestic ground, and 120 mL (4 oz) for air.
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.
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.
Liquid orientation arrows must be placed on two opposite sides of the overpack, even if they can be seen through the stretch wrap.
Remington policy is to apply the overpack, LQ and liquid 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.
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® has the possibility to ship as a non-hazardous material for road or rail transport in the USA.
However, Remington’s company policy is for RemOil 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.
COMMODITY: Empty drums with residue of smokeless powder, for return to manufacturer.
MODE OF TRANSPORTATION: Domestic Road – Truck load (TL) service only, not LTL
OVERVIEW
PROPER SHIPPING NAME:
None
LABEL:
N/A, or as per manufacturer
IDENTIFICATION NUMBER:
None
PLACARD:
None
HAZARD CLASS/DIVISION:
None
EMERG. INFO:
None
PACKING GROUP:
None
TRAINING:
Required
DOCUMENT:
Special
PACKAGING:
PI 114(b)
MARKING:
N/A, or as per manufacturer
HAZARDOUS MATERIALS TABLE
(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)Vessel stowage
Excep-tions
Non- bulk
Bulk
Passenger aircraft/ rail
Cargo aircraft only
Loca- tion
Other
(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8A)
(8)
(8C)
(9A)
(9B)
(10A)
(10B)
Powder, smokeless
1.3C
UN0161
1.3C
None
62
None
Forbidden
Forbidden
02
25
EMPTY PACKAGE EXCEPTION
Empty packages of hazard materials with residue are subject to the regulations the same as they were shipped when full. However, exceptions exist in 49 CFR 173.29 which prescribe certain conditions under which the hazardous materials regulations do not apply. A special paragraph (f) details specific provisions for shipping empty drums containing residue of smokeless powder. The benefit is that a normal carrier may be used at a lower cost than a specialist carrier licensed for hauling explosives; for example, a hazardous materials safety permit is required for the transport of Division 1.3 smokeless powder, but the return shipments of empty drums do not require this. In addition to the requirements in the sections below, the following apply:
(1) The empty packages must be transported in a closed transport vehicle (not on a flatbed);
(2) The empty packages must be loaded by the shipper and unloaded by the shipper or consignee (ship a full trailer of drums, don’t use LTL)
Smokeless powder is required to have received an explosives approval by the US DOT, including for transport as residue in empty drums. However, when transporting empty drums using these provisions, no hazard class or UN number is applicable.
The packaging must be a UN specification 1G fiber drum or 1A2 steel drum. The amount of smokeless powder per package may not exceed 5 grams. A provision also exists for the return of bottles in boxes, up to 2.5 grams per bottle and not exceeding 5 grams per box.
Smokeless powder is not subject to shipping papers other than as required by 49 CFR 173.29(f)(6) the The description on the shipping paper must be exactly:
“RESIDUE: Last Contained Powder, smokeless, Hazard Class N/A, Identification Number N/A, Packing Group N/A”
HM
DESCRIPTION
WEIGHT/LBS.
RESIDUE: Last Contained Powder, smokeless, Hazard Class N/A, Identification Number N/A, Packing Group N/A
No hazard class or UN number is required, therefore no marks or labels are required. The drums may be presented for transport as they were marked and labeled by the manufacturer, but this is not required. For example, damaged hazard labels do not need to be repaired.
OVERPACK MARKINGS
An overpack is:
a pallet
a spec packaging within a non-spec packaging, normally used for consolidation
Empty drums are not normally palletized, as the trailer is completely filled. Overpacks, if used, are not subject to marking.
REMINGTON HAZARDOUS MATERIALS TRANSPORT DATA SHEET
COMMODITY: Smokeless powder for small arms; classified by EX approval as a flammable solid; up to 8 pounds per bottle and 100 pounds net per shipment.
MODE OF TRANSPORTATION: Domestic Road, Rail, Vessel and Air, with limitations
OVERVIEW
PROPER SHIPPING NAME:
Smokeless powder for small arms
LABEL:
Yes
IDENTIFICATION NUMBER:
NA 3178
PLACARD:
If with other hazmat exceeding 1000 lbs. gross aggregate
HAZARD CLASS/DIVISION:
4.1
EMERG. INFO:
Yes
PACKING GROUP:
I
TRAINING:
Required
DOCUMENT:
Yes
PACKAGING:
Special
MARKING:
Yes
HAZMAT TABLE
(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
Excep-tions
Non- bulk
Bulk
Passenger aircraft/ rail
Cargo aircraft only
Loca- tion
Other
(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8A)
(8)
(8C)
(9A)
(9B)
(10A)
(10B)
D
Smokeless powder for small arms (100 pounds or less)
4.1
NA3178
I
4.1
16
None
171
None
Forbidden
7.3 kg
A
CLASSIFICATION
Per 49 CFR 173.171, Smokeless powder for small arms which has been classed in Division 1.3 or Division 1.4 may be reclassed in Division 4.1 (flammable solid), subject to certain conditions. An EX approval is required, but the EX number does not need to be marked per 172.320 since it is a flammable solid and no longer an explosive.
Road: Maximum 100 pounds net mass per transport vehicle, e.g. a trailer. A motor vehicle with multiple trailers could have 100 pounds in each trailer, or a truck with cargo compartment could have 100 pounds and haul a trailer with an additional 100 pounds.
Rail: Maximum 100 pounds net mass per transport vehicle, e.g. a rail car.
Vessel: Maximum 100 pounds net mass per freight container, not to exceed four freight containers per vessel.
Air: Passenger aircraft is forbidden. Maximum 100 pounds net mass per cargo aircraft. Per Column 9b of the hazardous materials, each package is limited to 7.3 kg (16 pounds).
Smokeless powder may be transported as Division 4.1 flammable solids when packaged as follows:
in a configuration examined and approved in an EX approval.
in a Packing Group I certified package (per the hazardous materials table). While explosives are packaged as PG II by default, this alternative method uses PG I packaging, a higher standard than PG II.
only combination packagings with inner packagings not exceeding 3.6 kg (8 pounds) net mass are authorized. Inner packagings must be arranged and protected so as to prevent simultaneous ignition of the contents.
49 CFR 173.171 allows the configurations authorized in an EX approval to be modified as follows. Different brands and sizes of approved flammable solid smokeless powder inner packages may be combined in a 4G fiberboard box tested to Packing Group I, but not necessarily tested with the mixture of packages just described. All inside containers must be packed to prevent shifting (e.g. with packing materials), and the net weight of smokeless powder in any one box may not exceed 7.3 kg (16 pounds) or the certified gross weight capacity of the specification outer packaging, whichever is lower. There is no 16 pound limit for authorized packages which do not use this provision, except on aircraft, e.g. a box might contain six 5-pound bottles, but if this is modified with other brands or sizes then the 16 pounds net limit applies.
1) Shipping description together and in order with no other information interspersed:
“NA 3178, Smokeless powder for small arms, 4.1, PG I”.
2) The total quantity before or after the shipping description, in pounds and/or kilograms (lb or kg), covered by the shipping description.
3) The number and type of packages, before or after the shipping description, e.g. “10 boxes” or “10 drums”. Commonly understood abbreviations may be used, e.g. “bx” or “drm”.
4) Since this is a flammable solid, there is no EX marking or shipping paper requirement, and no net explosives quantity required.
HM
DESCRIPTION
WEIGHT/LBS.
X
NA 3178, Smokeless powder for small arms, 4.1, PG I
* 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.
OVERPACKS
The “OVERPACK” marking is only required if the package markings and label are not visible at least once, in which case the “overpack” marking (e.g. sticker) is required on only one side of the pallet or overpack box, and the UN number, proper shipping name and hazard label must be replicated, preferably next to the overpack marking..
Remington policy is to apply the overpack and package markings and labels 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.
COMMODITY: Empty primed brass as 1.4S; 25 kg net maximum per package.
MODE OF TRANSPORTATION: International Air
CLASSIFICATION & REQUIREMENTS
PROPER SHIPPING NAME:
Cases, cartridge, empty with primer
LABEL:
1.4S
IDENTIFICATION NUMBER:
UN0055
PLACARD:
N/A
HAZARD CLASS/DIVISION:
1.4S
EMERGENCY:
Yes
PACKING GROUP:
None
TRAINING:
Every 2 Years
DOCUMENT:
Special
PACKAGING:
PI 136
MARKING:
Yes
DANGEROUS GOODS LIST
CLASSIFICATION
Empty primed cases which meet Division 1.4 criteria are not regulated in the US as hazardous materials. They are regulated for international air transportation as a Division 1.4S explosive. The ICAO requires competent authority approval of explosives. The US DOT hazardous materials table assigns Special Provision to UN 0055, which constitutes a competent authority approval satisfying the ICAO. No EX approval is required, and this is corroborated by an interpretation.
The package must be tested, and bear the specification package mark.
The maximum gross weight is 25 kg for passenger aircraft or 100 kg for cargo-aircraft-only).
Empty primed cartridges must be packed per Packing Instruction 136; inner, and outer packagings are required, intermediate packagings are not necessary:
The packaging codes are specifications with minimum standards of construction and maximum gross weights.
International air transport is subject to the requirements of IATA, the International Air Transport Association. A special document is required called a Dangerous Goods Declaration (DGD) in addition to any standard bill of lading. Fill out the DGD as follows in four sequences:
Sequence 1 – Dangerous Goods Identification
The sequence is: “UN 0055, CASES, CARTRIDGE, EMPTY WITH PRIMER, 1.4S”. There is no packing group.
For multiple products, each change to Sequence 1 must be on a new line.
Sequence 2 – Quantity and Type of Packing
The sequence is “QUANTITY PACKAGING:MATERIAL-TYPE X NET-QUANTITY, NEQ”, e.g. “5 fibreboard boxes X 11 kg, 1 kg NEQ”. Quantity is the number of shipping cases (packages). The degree of rounding is not specified, but may be to the nearest kilogram, and should be consistent between the DGD, package and overpack markings. Packaging type is material and type, e.g. “fibreboard boxes” or “steel drums”. Metric units must be used, which for solids is “kg”, not capitalized. For ammunition, NEQ is the primer mix.
For multiple products, each change to Sequence 2 must be on a different line, e.g. different net weight, but Sequence 1 does not have to be repeated if together. See IATA DGR Figure 8.1.K.
When overpacks are used:
Packaging in overpacks must be listed first.
The wording “Overpack Used” must be inserted on the declaration form immediately after all the entries in the overpack.
When a consignment consists of multiple overpacks each overpack must have an identification marking any alpha-numeric format) and be marked with the total quantity of dangerous goods within the overpack including the unit of measurement.
The total quantity(ies) shown on the Shipper’s Declaration must match the total quantity(ies) shown on the overpack.
Multiple overpacks with identical contents must be identified as follows: “Overpack Used X (number of identical overpacks)”, (see IATA Figure 8.1.L and Figure 8.1.N, examples 8 and 10). Multiple overpacks with different contents must be identified by listing them separately
Sequence 3 –Packing Instruction
Write the number of the applicable packing instruction, “136”.
Sequence 4 – Authorizations
The competent authority letter under the link “interpretation” cited above must be attached.
Citation: IATA 8.1.6.9
CARTON MARKING & LABELING
Packages containing empty primed cartridges must display the following markings and at least 6mm (1/4”) high, or an appropriate size for packages which are ≤5 kg net, as follows:
Proper shipping name – “CASES, CARTRIDGE, EMPTY WITH PRIMER ”
UN# – “UN 0055”
the full name and address of the shipper and the consignee, located on the same package surface and near the proper shipping name, if the package dimensions are adequate;
the net quantity, in kilogram units abbreviated “kg” in lower case letters, e.g. “15.2 kg”. This quantity must be marked adjacent to the UN number and proper shipping name. It may be rounded to the nearest kilogram, or to a desired level of decimals for better accuracy and alignment with the overpack weight. The net quantity should be identical to that shown on the Dangerous Goods Declaration document.
the specification package marking, placed in a location and of such size relative to the package as to be readily visible. Must be pre-printed or affixed, and not handwritten. For packages with a gross weight exceeding 30 kg the marking, or a duplicate thereof, must appear on the top or on the side of the package. For example:
The 1.4S hazard label must be applied as follows:
When the package dimensions are adequate, labels must be located on the same surface of the package near the proper shipping name marking.
Labels should be affixed adjacent to the shipper’s or consignee’s address appearing on the package.
Unless the package dimensions are inadequate, the label(s) must be affixed at an angle of 45 degrees (diamond shaped) to the surrounding markings.
Citation: IATA 6.0.4.1, 7.1.4, 7.1.5, 7.2.6.2
OVERPACK MARKINGS
Examples of overpacks include pallets and specification packages placed in another packaging. International air transport is subject to the requirements of IATA, the International Air Transport Association, which requires unique pallet markings.
Unless all markings and labels representative of all dangerous goods in the overpack are clearly visible, the overpack must be marked with:
the word “OVERPACK” in letters at least 12 mm (1/2”) high;
UN number
proper shipping name
full names and addresses of the consignor and consignee
The following requirements apply even if all markings are visible:
If there is more than one UN number in an overpack, write each UN number and the total quantity of dangerous goods for each UN number.
If there are two or more overpacks, name and mark each pallet with a unique identification mark (which may be in any alpha-numeric format) and the total quantity of dangerous goods, as indicated on the Dangerous Goods Declaration.
Normally we would use this OVERPACK sticker for domestic shipments:
However since there is so much information required, we print it on a piece of paper instead, with OVERPACK and the UN number in 1/2″ print, and affix it to the pallet:
