UN 1993: LQ REMOIL®, W/ OR W/O MOISTUREGUARD; BY DOMESTIC GROUND

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 1993PLACARD:No
HAZARD CLASS/DIVISION:3EMERG. INFO: No
PACKING GROUP:IIITRAINING:Required
DOCUMENT:NoPACKAGING: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-tionsNon-
bulk
BulkPassenger aircraft/ rail
Cargo aircraft onlyLoca-
tion
Other
(1)(2)(3)(4)(5)(6)(7)(8A)(8)(8C)(9A)(9B)(10A)(10B)
GFlammable liquid, n.o.s.
3UN1993III3 B1, B52, IB3, T4, TP1, TP29
15020324260L220LA

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.

Citation: 49 CFR 173.63 (b)(2)

SHIPPING PAPER REQUIREMENTS

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.

HMDESCRIPTIONWEIGHT/LBS.
 RemOil flammable liquid (?)(Insert gross or net weight)

Citation: 49 CFR 173.63(b)(1)(i)

CARTON MARKING

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.

Citation:  49 CFR §172.301(d),  §172.312§172.315 (a) & 49 CFR §173.150

OVERPACKS

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.

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® 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.

Citation: 49 CFR references: 172.101173.120(b)173.121(f)173.150