A New Rule that Clarifies Classification of Formaldehyde and Formalin Solutions
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
- 5 common classification scenarios
- easy to follow guidelines
- overview of dangerous goods regulations