UN 3175: WIPES IN PACKETS (NOT REGULATED)

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.

PROPER SHIPPING NAME:Solids containing flammable liquid, n.o.s. (petroleum distillates)LABEL:Flammable solid
IDENTIFICATION NUMBER:UN 3175PLACARD:Flammable solid
HAZARD CLASS/DIVISION:4.1EMERG. INFO:Yes
PACKING GROUP:IITRAINING:Yes
DOCUMENT:YesPACKAGING:Yes
MARKING:Yes  

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)Vesselstowage
Excep-tionsNon-
bulk
BulkPassenger aircraft/ rail
Cargo aircraft onlyLoca-
tion
Other
(1)(2)(3)(4)(5)(6)(7)(8A)(8)(8C)(9A)(9B)(10A)(10B)
Solids containing flammable liquid, n.o.s.3UN3175II4.147, IB6, IP2, T3, TP33
15121224015 kg50 kgB

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:

  1. First, there can be no free liquid at the time of filling to be classed into UN 3175, unless  flammable solid testing is done.
  2. To then exit the regulations:
    1. Package in a sealed packet
    2. Have no more than 10 mL of liquid absorbed
    3. Liquid must be PG II or III (not PG I)
    4. 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.

Citation: 49 CFR 172.102 SP47; IMDG SP216; ICAO TI SP A47