30 Spray June 2017 Steven CharleS hunt President, ShipMate, Inc. From here to there: Topics in Transportation Management of Waste Aerosols Aerosols intended for disposal or recycling are subject to the 49 CFR subchapter C Hazardous Materials Regulations (HMR). Accordingly, they must be properly packaged, marked, labeled and documented for transport. However, the provisions of 49 CFR §173.306 offer some regulatory relief for limited quantities of aerosols in U.S. Dept. of Transportation (DOT) specification 2P and 2Q metal cans; non-flammable aerosols in non-specification and DOT specification 2S plastic aerosols; and certain aerosols for foodstuffs, soaps, biological and toiletries that conform to 49 CFR §173.306 (a)(3), (a)(5), (b)(1), (b)(2), or (b)(3). Aerosols Intended for Disposal Aerosols conforming to those sections may be excepted from the labeling requirements; the specification packaging requirements of the HMR when packaged as described below; the shipping paper requirements of the HMR (unless the material meets the definition of a hazardous substance or hazardous waste); and the 30kg (66lbs) gross weight limitation when transported by motor vehicle for purposes of recycling or disposal under the following conditions: • The aerosols must be packaged in a strong outer packaging. The strong outer packaging and its contents must not exceed a gross weight of 500kg (1,100lbs); • Each aerosol must be secured with a cap to protect the valve stem or the valve stem must be removed; • Each completed package must be marked in accordance with §172.315(a); and • The packaging must be offered for transportation or transported by a private or contract motor carrier; or an exclusive-use common carrier. It is important to note that each aerosol can must be secured se cured with a protective cap or have the valve stems clipped. Aerosols Transported in Drums Certain DOT Specification 2P, 2Q and 2S and other nonspecification aerosols that conformed to the HMR at the time of filling, but which are leaking, have been improperly filled or otherwise no longer conform to the HMR may be offered for transportation and transported for disposal or recycling in drums under the conditions provided in 49 CFR §173.306(k)(2). These aerosols are not eligible for the labeling, marking or other exceptions provided for in 49 CFR §173.306 (a) and (i). Notwithstanding the marking requirements for nonbulk packages in 49 CFR §172.301, each drum must be bulk marked “AEROSOL SALVAGE” or “AEROSOL SALVAGE SAL VAGE DRUM” in association with the required label(s). The overpack marking requirements of 49 CFR §173.25 do not apply. They are, however, excepted from the placarding requirements of the HMR. The completed drums must be offered for transportation and transported by private or contract carrier by highway or rail, while vessel and air transportation are not authorized. Aerosols intended for disposal or recycling must be packaged as follows: • These aerosols must be packaged in a metal or plastic removable head United Nations’ 1A2 (steel), 1B2 (aluminum), 1N2 (other metal) or 1H2 (plastic) drums tested and marked to the PG II performance level or higher for liquids; • Each drum must be provided, when necessary, with sufficient cushioning and absorption material to prevent excessive shifting of the aerosols and to eliminate the presence of any free liquid at the time the drum is closed. All cushioning and absorbent material used in
Spray June 2017
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