34 Spray May 2018
Gene Sanders
W.E. Train Consulting
Gene@WEtrainConsulting.com
From here to there:
Topics in
Transportation
I’ve Got Gas!
Once upon a time, more than a decade ago, I had two aerosol
containers to classify. The outer containers, contents and
release valve were all exactly the same, but the classifications
were very different. Inside the container, from the release valve down
into the contents, there was a narrow tube. In one container the tube
was very short. It only reached down into the gaseous portion of the
“gas” inside. Below the end of the tube was the liquefied portion of
the “gas.” The other container had a long tube, almost exactly the
height of the container. The long tube passed through the gaseous
portion, deep into the liquefied portion. What possible effect could
the tube length have on the transport classification?
In the most rudimentary analysis, it didn’t have much effect at all.
Both containers were classified with the name of the gas inside and
the UN identification number that matched it. The exact names of
the gas and UN identification number aren’t important here. What
is important is that a cost-effective operation doesn’t always just stop
at the root or intrinsic transport classification, but looks for potential
exceptions that may simplify shipping or save money when shipping
or both—and that’s where the tube length had its effect.
When the relief valve was pushed on the aerosol-style container
with the short tube, the pressure in the container forced the gaseous
material up the tube and out. This flow of gas blew stuff away and
carried moisture with it. Although the product was sold to dry off
moist electrophoresis gels, it would have worked just fine to blow the
sandwich crumbs off of my computer keyboard. The latter is a use
suitable for home, which means one of the Consumer Commodity
exceptions is a possibility, and sure enough, we met the rest of the
required conditions and used the ORM-D exception.
However, when the relief valve was pushed on the container with
the long tube, what came up the tube was liquefied gas. Whatever
this liquid landed on was immediately frozen hard, including human
tissue. While this was wonderful for the intended purpose—to freeze
samples of moles, warts and skin growths hard enough that they
could be cut into very thin slices before viewing under a microscope—