A New Rule that Clarifies Classification of Formaldehyde and Formalin Solutions

20 Jul, 2011 by  admin@quick.aero

US DOT Pipeline and Hazardous Materials Safety Administration (PHMSA) issued its HM-218F final rule in the Federal Register today (July 20, 2011). 

This is a miscellaneous rulemaking covering such things as classification of formaldehyde solutions, clarification of the use of standards for fireworks classification, and hazard communication requirement clarifications.  The effective date of the provisions adopted in HM-218F is August 19, 2011, with an immediate voluntary compliance date (July 20, 2011).  

One significant change to the Life Science shippers is the clarification of regulations for Formaldehyde and Formalin:

The entries for ‘‘Formaldehyde, solutions’’ and  ‘‘Formalin’’  are sometimes used incorrectly. Formalin is specifically defined as a 37%  aqueous solution of formaldehyde. A 10% formalin solution and  10% formaldehyde solution are not the same materials for transport purposes. Many diagnostic and  biological samples are transported by commercial aircraft in formaldehyde solutions of various concentrations. Some samples transported in 10%  or greater formaldehyde solutions are incorrectly shipped as unregulated materials. Other samples transported in 3.7% formaldehyde (10%  formalin) solutions are incorrectly shipped as fully regulated hazardous materials. 

A formaldehyde solution, with less than 25%  but not less than 10% formaldehyde is a Class 9 material. PHMSA  proposed to include a new italicized entry in Column (2) of the HMT for 10%–25% formaldehyde solutions to enhance understanding of the entries in the HMT. This  new  entry would reference the proper shipping names ‘‘Aviation regulated liquid, n.o.s’’ and  ‘‘Other regulated substances, liquid, n.o.s.’’

Formalin is an aqueous solution of formaldehyde and  methanol and  is a Class 3 flammable liquid material. The entry ‘‘Formaldehyde solutions, flammable, UN1198’’ is intended for use as a hazardous materials description for formalin. Note that  the less common ‘‘methanol-free’’ formalin is not a Class 3 material. Therefore, for further clarification, we proposed to revise the ‘‘Formaldehyde, solutions, flammable’’ entry by adding a new  special provision 176 to specify that  the entry is intended for use as proper shipping name for formaldehyde solutions containing methanol.  

PHMSA  became aware of a typographical error  in the entry ‘‘Formaldehyde solutions’’ which has an extra  comma between ‘‘Formaldehyde’’ and  ‘‘solutions.’’ Therefore, PHMSA proposed to correct this  error  by removing the comma between ‘‘Formaldehyde’’ and  ‘‘solutions’’ in the proper shipping name for UN1198. PHMSA  received no comments on these proposed changes to the HMT. Therefore, we are adopting these amendments, with an edit  to ‘‘Formaldehyde solutions, UN1198,’’ entry as proposed.​

The full text of the Final Rule can be accessed here http://www.gpo.gov/fdsys/pkg/FR-2011-07-20/pdf/2011-17687.pdf 

Logistics Tips:   Classifying Biological Substances as Dangerous Goods
Easy to follow guide on how to classify biological commodities for transport as dangerous goods:

  - 5 common classification scenarios  
  - easy to follow guidelines
  - overview of dangerous goods regulations 

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