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PHMSA is amending the Hazardous Materials Regulations (HMR) to maintain alignment with international regulations and standards by adopting various amendments, including changes to proper shipping names, hazard classes, packing groups, special provisions, packaging authorizations, air transport quantity limitations, and vessel stowage requirements. PHMSA is also withdrawing the unpublished November 28, 2022, Notice of Enforcement Policy Regarding International Standards on the use of select updated international standards in complying with the HMR during the pendency of this rulemaking.

DATES:

Effective date: This rule is effective May 10, 2024.

Voluntary compliance date: January 1, 2023.

Delayed compliance date: April 10, 2025.

This final rule is published in the Federal Register April 10, 2024.

View final rule.

§171.7 Reference material.
(t)(1), (v)(2), and (w)(32) through (81) Revised View text
(w)(82) through (92) Added View text
(aa)(3) and (dd)(1) through (4) Revised View text
§171.12 North American shipments.
(a)(4)(iii) Revised View text
§171.23 Requirements for specific materials and packagings transported under the ICAO technical instructions, IMDG code, Transport Canada TDG regulations, or the IAEA regulations.
(a)(3) Revised View text
§171.25 Additional requirements for the use of the IMDG code.
(c)(3) and (4) Revised View text
(c)(5) Added View text
§172.101 Purpose and use of the hazardous materials table.
Section heading Revised View text
(c)(12)(ii) Revised View text
Hazardous materials table, multiple entries Revised, added, removed View text
§172.102 Special provisions.
(c)(1) special provisions 78, 156, and 387 Revised View text
(c)(1) special provisions 396 and 398 Added View text
(c)(1) special provision 421 Removed and reserved View text
(c)(2) special provision A54 Revised View text
(c)(2) special provisions A224 and A225 Added View text
(c)(4) Table 2—IP Codes, special provision IP15 Revised View text
(c)(4) Table 2—IP Codes, special provision IP22 Added View text
§173.4b De minimis exceptions.
(b)(1) Revised View text
§173.21 Forbidden materials and packages.
(f) introductory text, (f)(1), and (f)(2) Revised View text
§173.27 General requirements for transportation by aircraft.
(f)(2)(i)(D) Revised View text
§173.124 Class 4, Divisions 4.1, 4.2 and 4.3— Definitions.
(a)(4)(iv) Removed View text
§173.137 Class 8—Assignment of packing group.
Introductory text Revised View text
§173.151 Exceptions for Class 4.
(d) introductory text Revised View text
§173.167 ID8000 consumer commodities.
Entire section Revised View text
§173.185 Lithium cells and batteries.
(a)(3) introductory text and (a)(3)(x) Revised View text
(a)(5) Added View text
(b)(3)(iii)(A) and (B) Revised View text
(b)(3)(iii)(C) Added View text
(b)(4)(ii) and (iii) Revised View text
(b)(4)(iv) Added View text
(b)(5), (c)(3) through (5), and (e)(5) through (7) Revised View text
§173.224 Packaging and control and emergency temperatures for self-reactive materials.
(b)(4) Revised View text
Table following (b)(7) Revised View text
§173.225 Packaging requirements and other provisions for organic peroxides.
Table 1 to paragraph (c) Revised View text
Table following paragraph (d) Retitled View text
Table following paragraph (g) Revised View text
§173.232 Articles containing hazardous materials, n.o.s.
(h) Added View text
§173.301b Additional general requirements for shipment of UN pressure receptacles.
(c)(1), (c)(2)(ii) through (iv), (d)(1), and (f) Revised View text
§173.302b Additional requirements for shipment of non-liquefied (permanent) compressed gases in UN pressure receptacles.
(g) Added View text
§173.302c Additional requirements for the shipment of adsorbed gases in UN pressure receptacles.
(k) Revised View text
§173.311 Metal Hydride Storage Systems.
Entire section Revised View text
§175.1 Purpose, scope, and applicability.
(e) Added View text
§175.10 Exceptions for passengers, crewmembers, and air operators.
(a) introductory text, (a)(14) introductory text, (a)(15)(v)(A), (a)(15)(vi)(A), (a)(17)(ii)(C), (a)(18) introductory text, and (a)(26) introductory text Revised View text
§175.33 Shipping paper and information to the pilot-in-command.
(a)(13)(iii) Revised View text
§178.37 Specification 3AA and 3AAX seamless steel cylinders.
(j) Revised View text
§178.71 Specifications for UN pressure receptacles.
(f)(4), (g), (i), (k)(1)(i) and (ii), (m), and (n) Revised View text
§178.75 Specifications for MEGCs.
(d)(3) introductory text and paragraphs (d)(3)(i) through (iii) Revised View text
§178.609 Test requirements for packagings for infectious substances.
(d)(2) Revised View text
§178.706 Standards for rigid plastic IBCs.
(c)(3) Revised View text
§178.707 Standards for composite IBCs.
(c)(3)(iii) Revised View text
§180.207 Requirements for requalification of UN pressure receptacles.
(d)(3) and (5) Revised View text
(d)(8) Added View text

Previous Text

§171.7 Reference material.

* * * * *

(t) * * *

(1) ICAO Doc 9284. Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICAO Technical Instructions), 2021-2022 Edition, copyright 2020; into §§171.8; 171.22 through 171.24; 172.101; 172.202; 172.401; 172.407; 172.512; 172.519; 172.602; 173.56; 173.320; 175.10, 175.33; 178.3.

* * * * *

(v) * * *

(2) International Maritime Dangerous Goods Code (IMDG Code), Incorporating Amendment 40-20 (English Edition), (Volumes 1 and 2), 2020 Edition, copyright 2020; into §§171.22; 171.23; 171.25; 172.101; 172.202; 172.203; 172.401; 172.407; 172.502; 172.519; 172.602; 173.21; 173.56; 176.2; 176.5; 176.11; 176.27; 176.30; 176.83; 176.84; 176.140; 176.720; 176.906; 178.3; 178.274.

(w) * * *

(32) ISO 9809-2:2000(E): Gas cylinders—Refillable seamless steel gas cylinders—Design, construction and testing—Part 2: Quenched and tempered steel cylinders with tensile strength greater than or equal to 1 100 MPa., First edition, June 2000, into §§178.71; 178.75.

(33) ISO 9809-2:2010(E): Gas cylinders—Refillable seamless steel gas cylinders—Design, construction and testing—Part 2: Quenched and tempered steel cylinders with tensile strength greater than or equal to 1100 MPa., Second edition, 2010-04-15, into §§178.71; 178.75.

(34) ISO 9809-3:2000(E): Gas cylinders—Refillable seamless steel gas cylinders—Design, construction and testing—Part 3: Normalized steel cylinders, First edition, December 2000, into §§178.71; 178.75.

(35) ISO 9809-3:2010(E): Gas cylinders—Refillable seamless steel gas cylinders—Design, construction and testing—Part 3: Normalized steel cylinders, Second edition, 2010-04-15, into §§178.71; 178.75.

(36) ISO 9809-4:2014(E), Gas cylinders—Refillable seamless steel gas cylinders—Design, construction and testing—Part 4: Stainless steel cylinders with an Rm value of less than 1 100 MPa, First edition, 2014-07-15, into §§178.71; 178.75.

(37) ISO 9978:1992(E)—Radiation protection—Sealed radioactive sources—Leakage test methods. First Edition, (February 15, 1992), into §173.469.

(38) ISO 10156:2017(E), Gas cylinders—Gases and gas mixtures—Determination of fire potential and oxidizing ability for the selection of cylinder valve outlets, Fourth edition, 2017-07; into §173.115.

(39) ISO 10297:1999(E), Gas cylinders—Refillable gas cylinder valves—Specification and type testing, First Edition, 1995-05-01; into §§173.301b; 178.71.

(40) ISO 10297:2006(E), Transportable gas cylinders—Cylinder valves—Specification and type testing, Second Edition, 2006-01-15; into §§173.301b; 178.71.

(41) ISO 10297:2014(E), Gas cylinders—Cylinder valves—Specification and type testing, Third Edition, 2014-07-15; into §§173.301b; 178.71.

(42) ISO 10297:2014/Amd 1:2017(E), Gas cylinders—Cylinder valves—Specification and type testing—Amendment 1: Pressure drums and tubes, Third Edition, 2017-03; into §§173.301b; 178.71.

(43) ISO 10461:2005(E), Gas cylinders—Seamless aluminum-alloy gas cylinders—Periodic inspection and testing, Second Edition, 2005-02-15 and Amendment 1, 2006-07-15; into §180.207.

(44) ISO 10462:2013(E), Gas cylinders—Acetylene cylinders—Periodic inspection and maintenance, Third edition, 2013-12-15; into §180.207.

(45) ISO 10692-2:2001(E), Gas cylinders—Gas cylinder valve connections for use in the micro-electronics industry—Part 2: Specification and type testing for valve to cylinder connections, First Edition, 2001-08-01; into §§173.40; 173.302c.

(46) ISO 11114-1:2012(E), Gas cylinders—Compatibility of cylinder and valve materials with gas contents—Part 1: Metallic materials, Second edition, 2012-03-15; into §§172.102; 173.301b; 178.71.

(47) ISO 11114-1:2012/Amd 1:2017(E), Gas cylinders—Compatibility of cylinder and valve materials with gas contents—Part 1: Metallic materials—Amendment 1, Second Edition, 2017-01; into §§172.102; 173.301b; 178.71.

(48) ISO 11114-2:2013(E), Gas cylinders—Compatibility of cylinder and valve materials with gas contents—Part 2: Non-metallic materials, Second edition, 2013-04; into §§173.301b; 178.71.

(49) ISO 11117:1998(E): Gas cylinders—Valve protection caps and valve guards for industrial and medical gas cylinders—Design, construction and tests, First edition, 1998-08-01; into §173.301b.

(50) ISO 11117:2008(E): Gas cylinders—Valve protection caps and valve guards—Design, construction and tests, Second edition, 2008-09-01; into §173.301b.

(51) ISO 11117:2008/Cor.1:2009(E): Gas cylinders—Valve protection caps and valve guards—Design, construction and tests, Technical Corrigendum 1, 2009-05-01; into §173.301b.

(52) ISO 11118(E), Gas cylinders—Non-refillable metallic gas cylinders—Specification and test methods, First edition, October 1999; into §178.71.

(53) ISO 11118:2015(E), Gas cylinders—Non-refillable metallic gas cylinders—Specification and test methods, Second edition, 2015-09-15; into §§173.301b; 178.71.

(54) ISO 11119-1(E), Gas cylinders—Gas cylinders of composite construction—Specification and test methods—Part 1: Hoop-wrapped composite gas cylinders, First edition, May 2002; into §178.71.

(55) ISO 11119-1:2012(E), Gas cylinders—Refillable composite gas cylinders and tubes—Design, construction and testing—Part 1: Hoop wrapped fibre reinforced composite gas cylinders and tubes up to 450 l, Second edition, 2012-08-01; into §§178.71; 178.75.

(56) ISO 11119-2(E), Gas cylinders—Gas cylinders of composite construction—Specification and test methods—Part 2: Fully wrapped fibre reinforced composite gas cylinders with load-sharing metal liners, First edition, May 2002; into §178.71.

(57) ISO 11119-2:2012(E), Gas cylinders—Refillable composite gas cylinders and tubes—Design, construction and testing—Part 2: Fully wrapped fibre reinforced composite gas cylinders and tubes up to 450 l with load-sharing metal liners, Second edition, 2012-07-15; into §§178.71; 178.75.

(58) ISO 11119-2:2012/Amd.1:2014(E), Gas cylinders—Refillable composite gas cylinders and tubes—Design, construction and testing—Part 2: Fully wrapped fibre reinforced composite gas cylinders and tubes up to 450 l with load-sharing metal liners, Amendment 1, 2014-08-15; into §§178.71; 178.75.

(59) ISO 11119-3(E), Gas cylinders of composite construction—Specification and test methods—Part 3: Fully wrapped fibre reinforced composite gas cylinders with non-load-sharing metallic or non-metallic liners, First edition, September 2002; into §178.71.

(60) ISO 11119-3:2013(E), Gas cylinders—Refillable composite gas cylinders and tubes—Design, construction and testing—Part 3: Fully wrapped fibre reinforced composite gas cylinders and tubes up to 450 l with non-load-sharing metallic or non-metallic liners, Second edition, 2013-04-15; into §§178.71; 178.75.

(61) ISO 11119-4:2016(E), Gas cylinders—Refillable composite gas cylinders—Design, construction and testing—Part 4: Fully wrapped fibre reinforced composite gas cylinders up to 150 L with load-sharing welded metallic liners, First Edition, 2016-02-15; into §§178.71; 178.75.

(62) ISO 11120(E), Gas cylinders—Refillable seamless steel tubes of water capacity between 150 l and 3000 l—Design, construction and testing, First edition, 1999-03; into §§178.71; 178.75.

(63) ISO 11120:2015(E), Gas cylinders—Refillable seamless steel tubes of water capacity between 150 l and 3000 l—Design, construction and testing, Second Edition, 2015-02-01; into §§178.71; 178.75.

(64) ISO 11513:2011(E), Gas cylinders—Refillable welded steel cylinders containing materials for sub-atmospheric gas packaging (excluding acetylene)—Design, construction, testing, use and periodic inspection, First edition, 2011-09-12; into §§173.302c; 178.71; 180.207.

(65) ISO 11621(E), Gas cylinders—Procedures for change of gas service, First edition, April 1997; into §§173.302, 173.336, 173.337.

(66) ISO 11623(E), Transportable gas cylinders—Periodic inspection and testing of composite gas cylinders, First edition, March 2002; into §180.207.

(67) ISO 11623(E):2015, Gas cylinders—Composite construction—Periodic inspection and testing, Second edition, 2015-12-01; into §180.207.

(68) ISO 13340:2001(E), Transportable gas cylinders—Cylinder valves for non-refillable cylinders—Specification and prototype testing, First edition, 2004-04-01; into §§173.301b; 178.71.

(69) ISO 13736:2008(E), Determination of flash point—Abel closed-cup method, Second Edition, 2008-09-15; into §173.120.

(70) ISO 14246:2014(E), Gas cylinders—Cylinder valves—Manufacturing tests and examination, Second Edition, 2014-06-15; into §178.71.

(71) ISO 14246:2014/Amd 1:2017(E), Gas cylinders—Cylinder valves—Manufacturing tests and examinations—Amendment 1, Second Edition, 2017-06; into §178.71.

(72) ISO 16111:2008(E), Transportable gas storage devices—Hydrogen absorbed in reversible metal hydride, First Edition, 2008-11-15; into §§173.301b; 173.311; 178.71.

(73) ISO 16148:2016(E), Gas cylinders—Refillable seamless steel gas cylinders and tubes—Acoustic emission examination (AT) and follow-up ultrasonic examination (UT) for periodic inspection and testing, Second Edition, 2016-04-15; into §180.207.

(74) ISO 17871:2015(E), Gas cylinders—Quick-release cylinder valves—Specification and type testing, First Edition, 2015-08-15; into §173.301b.

(75) ISO 17879: 2017(E), Gas cylinders—Self-closing cylinder valves—Specification and type testing, First Edition, 2017-07; into §§173.301b; 178.71.

(76) ISO 18172-1:2007(E), Gas cylinders—Refillable welded stainless steel cylinders—Part 1: Test pressure 6 MPa and below, First Edition, 2007-03-01; into §178.71.

(77) ISO 20475:2018(E), Gas cylinders—Cylinder bundles—Periodic inspection and testing, First Edition, 2018-02; into §180.207.

(78) ISO 20703:2006(E), Gas cylinders—Refillable welded aluminum-alloy cylinders—Design, construction and testing, First Edition, 2006-05-01; into §178.71.

(79) ISO 21172-1:2015(E), Gas cylinders—Welded steel pressure drums up to 3000 litres capacity for the transport of gases—Design and construction—Part 1: Capacities up to 1000 litres, First edition, 2015-04-01; into §178.71.

(80) ISO 22434:2006(E), Transportable gas cylinders—Inspection and maintenance of cylinder valves, First Edition, 2006-09-01; into §180.207.

(81) ISO/TR 11364:2012(E), Gas cylinders—Compilation of national and international valve stem/gas cylinder neck threads and their identification and marking system, First Edition, 2012-12-01; into §178.71.

* * * * *

(aa) * * *

(3) OECD Guideline for the Testing of Chemicals 431 (Test No. 431): In vitro skin corrosion: reconstructed human epidermis (RHE) test method, adopted 29 July 2016; into §173.137.

* * * * *

(dd) * * *

(1) Recommendations on the Transport of Dangerous Goods, Model Regulations (UN Recommendations), 21st revised edition, copyright 2019; into §§171.8; 171.12; 172.202; 172.401; 172.407; 172.502; 172.519; 173.22; 173.24; 173.24b; 173.40; 173.56; 173.192; 173.302b; 173.304b; 178.75; 178.274; as follows:

(i) Volume I, ST/SG/AC.10.1/21/Rev.21 (Vol. I).

(ii) Volume II, ST/SG/AC.10.1/21/Rev.21 (Vol. II).

(2) Manual of Tests and Criteria (UN Manual of Tests and Criteria), 7th revised edition, ST/SG/AC.10/11/Rev.7, copyright 2019; into §§171.24, 172.102; 173.21; 173.56 through 173.58; 173.60; 173.115; 173.124; 173.125; 173.127; 173.128; 173.137; 173.185; 173.220; 173.221; 173.224; 173.225; 173.232; part 173, appendix H; 175.10; 176.905; 178.274.

(3) Globally Harmonized System of Classification and Labelling of Chemicals (GHS), 8th revised edition, ST/SG/AC.10/30/Rev.8, copyright 2019; into §172.401.

(4) Agreement concerning the International Carriage of Dangerous Goods by Road (ADR), copyright 2020; into §171.8; §171.23 as follows: [Change Notice][Previous Text]

(i) Volume I, ECE/TRANS/300 (Vol. I).

(ii) Volume II, ECE/TRANS/300 (Vol. II).

(iii) Corrigendum, ECE/TRANS/300 (Corr. 1).

* * * * *

§171.12 North American shipments.

* * * * *

(a) * * *

(4) * * *

(iii) Authorized CRC, BTC, CTC or TC specification cylinders that correspond with a DOT specification cylinder are as follows:

TC DOT (some or all of these specifications may instead be marked with the prefix ICC) CTC (some or all of these specifications may instead be marked with the prefix BTC or CRC)
TC-3AM DOT-3A [ICC-3] CTC-3A
TC-3AAM DOT-3AA CTC-3AA
TC-3ANM DOT-3BN CTC-3BN
TC-3EM DOT-3E CTC-3E
TC-3HTM DOT-3HT CTC-3HT
TC-3ALM DOT-3AL
DOT-3B
CTC-3AL
CTC-3B
TC-3AXM DOT-3AX CTC-3AX
TC-3AAXM DOT-3AAX
DOT-3A480X
CTC-3AAX
CTC-3A480X
TC-3TM DOT-3T
TC-4AAM33 DOT-4AA480 CTC-4AA480
TC-4BM DOT-4B CTC-4B
TC-4BM17ET DOT-4B240ET CTC-4B240ET
TC-4BAM DOT-4BA CTC-4BA
TC-4BWM DOT-4BW CTC-4BW
TC-4DM DOT-4D CTC-4D
TC-4DAM DOT-4DA CTC-4DA
TC-4DSM DOT-4DS CTC-4DS
TC-4EM DOT-4E CTC-4E
TC-39M DOT-39 CTC-39
TC-4LM DOT-4L
DOT-8
DOT-8AL
CTC-4L
CTC-8
CTC-8AL

* * * * *

§171.23 Requirements for specific materials and packagings transported under the ICAO technical instructions, IMDG code, Transport Canada TDG regulations, or the IAEA regulations.

(a) * * *

(3) Pi-marked pressure receptacles. Pressure receptacles that are marked with a pi mark in accordance with the European Directive 2010/35/EU (IBR, see §171.7) on transportable pressure equipment (TPED) and that comply with the requirements of Packing Instruction P200 or P208 and 6.2 of the ADR (IBR, see §171.7) concerning pressure relief device use, test period, filling ratios, test pressure, maximum working pressure, and material compatibility for the lading contained or gas being filled, are authorized as follows:

(i) Filled pressure receptacles imported for intermediate storage, transport to point of use, discharge, and export without further filling; and

(ii) Pressure receptacles imported or domestically sourced for the purpose of filling, intermediate storage, and export.

(iii) The bill of lading or other shipping paper must identify the cylinder and include the following certification: “This cylinder (These cylinders) conform(s) to the requirements for pi-marked cylinders found in 171.23(a)(3).”

* * * * *

§171.25 Additional requirements for the use of the IMDG code.

* * * * *

(c) * * *

(3) Except as specified in this subpart, for a material poisonous (toxic) by inhalation, the T Codes specified in Column 13 of the Dangerous Goods List in the IMDG Code may be applied to the transportation of those materials in IM, IMO and DOT Specification 51 portable tanks, when these portable tanks are authorized in accordance with the requirements of this subchapter; and

(4) No person may offer an IM or UN portable tank containing liquid hazardous materials of Class 3, PG I or II, or PG III with a flash point less than 100°F (38°C); Division 5.1, PG I or II; or Division 6.1, PG I or II, for unloading while it remains on a transport vehicle with the motive power unit attached, unless it conforms to the requirements in §177.834(o) of this subchapter.

* * * * *

§172.101 Purpose and use of hazardous materials table.

* * * * *

(c) * * *

(12) * * *

(ii) Generic or n.o.s. descriptions. If an appropriate technical name is not shown in the Table, selection of a proper shipping name shall be made from the generic or n.o.s. descriptions corresponding to the specific hazard class, packing group, hazard zone, or subsidiary hazard, if any, for the material. The name that most appropriately describes the material shall be used; e.g, an alcohol not listed by its technical name in the Table shall be described as “Alcohol, n.o.s.” rather than “Flammable liquid, n.o.s.”. Some mixtures may be more appropriately described according to their application, such as “Coating solution” or “Extracts, flavoring, liquid”, rather than by an n.o.s. entry, such as “Flammable liquid, n.o.s.” It should be noted, however, that an n.o.s. description as a proper shipping name may not provide sufficient information for shipping papers and package markings. Under the provisions of subparts C and D of this part, the technical name of one or more constituents which makes the product a hazardous material may be required in association with the proper shipping name.

* * * * *

§172.102 Special provisions.

* * * * *

(c) * * *

(1) * * *

(78) This entry may not be used to describe compressed air which contains more than 23.5 percent oxygen. Compressed air containing greater than 23.5 percent oxygen must be shipped using the description ‘‘Compressed gas, oxidizing, n.o.s., UN3156.’’

* * * * *

(156) Asbestos that is immersed or fixed in a natural or artificial binder material, such as cement, plastic, asphalt, resins or mineral ore, or contained in manufactured products is not subject to the requirements of this subchapter.

* * * * *

(387) When materials are stabilized by temperature control, the provisions of §173.21(f) of this subchapter apply. When chemical stabilization is employed, the person offering the material for transport shall ensure that the level of stabilization is sufficient to prevent the material as packaged from dangerous polymerization at 50°C (122°F). If chemical stabilization becomes ineffective at lower temperatures within the anticipated duration of transport, temperature control is required and is forbidden by aircraft. In making this determination factors to be taken into consideration include, but are not limited to, the capacity and geometry of the packaging and the effect of any insulation present, the temperature of the material when offered for transport, the duration of the journey, and the ambient temperature conditions typically encountered in the journey (considering also the season of year), the effectiveness and other properties of the stabilizer employed, applicable operational controls imposed by regulation (e.g., requirements to protect from sources of heat, including other cargo carried at a temperature above ambient) and any other relevant factors. The provisions of this special provision will be effective until January 2, 2023, unless we terminate them earlier or extend them beyond that date by notice of a final rule in the Federal Register.

* * * * *

(421) This entry will no longer be effective on January 2, 2023, unless we terminate it earlier or extend it beyond that date by notice of a final rule in the Federal Register.

* * * * *

(2) * * *

A54 Irrespective of the quantity limits in Column 9B of the §172.101 table, a lithium battery, including a lithium battery packed with, or contained in, equipment that otherwise meets the applicable requirements of §173.185, may have a mass exceeding 35 kg if approved by the Associate Administrator prior to shipment.

* * * * *

(4) * * *

IP15 For UN2031 with more than 55% nitric acid, the permitted use of rigid plastic IBCs, and the inner receptacle of composite IBCs with rigid plastics, shall be two years from their date of manufacture.

* * * * *

§173.4b De minimis exceptions.

* * * * *

(b) * * *

(1) The specimens are:

(i) Wrapped in a paper towel or cheesecloth moistened with alcohol or an alcohol solution and placed in a plastic bag that is heat-sealed. Any free liquid in the bag must not exceed 30 mL; or

(ii) Placed in vials or other rigid containers with no more than 30 mL of alcohol or alcohol solution. The containers are placed in a plastic bag that is heat-sealed;

* * * * *

§173.21 Forbidden materials and packages.

* * * * *

(f) A package containing a material which is likely to decompose with a self-accelerated decomposition temperature (SADT) of 50°C (122 °F) or less, or polymerize at a temperature of 54°C (130 °F) or less with an evolution of a dangerous quantity of heat or gas when decomposing or polymerizing, unless the material is stabilized or inhibited in a manner to preclude such evolution. The SADT may be determined by any of the test methods described in Part II of the UN Manual of Tests and Criteria (IBR, see §171.7 of this subchapter).

(1) A package meeting the criteria of paragraph (f) of this section may be required to be shipped under controlled temperature conditions. The control temperature and emergency temperature for a package shall be as specified in the table in this paragraph based upon the SADT of the material. The control temperature is the temperature above which a package of the material may not be offered for transportation or transported. The emergency temperature is the temperature at which, due to imminent danger, emergency measures must be initiated.

Table 1 to Paragraph (f)(1)—Method of Determining Control and Emergency Temperature
SADT 1 Control temperatures Emergency temperature
SADT ≤20°C (68°F) 20°C (36°F) below SADT 10°C (18°F) below SADT.
20°C (68°F) <SADT ≤35°C (95°F) 15°C (27°F) below SADT 10°C (18°F) below SADT.
35°C (95°F) <SADT ≤50°C (122°F) 10°C (18°F) below SADT 5°C (9°F) below SADT.
50°C (122°F) <SADT (2) (2)
1 Self-accelerating decomposition temperature.
2 Temperature control not required.

(2) For self-reactive materials listed in §173.224(b) Table control and emergency temperatures, where required are shown in Columns 5 and 6, respectively. For organic peroxides listed in The Organic Peroxides Table in §173.225 control and emergency temperatures, where required, are shown in Columns 7a and 7b, respectively.

* * * * *

§173.27 General requirements for transportation by aircraft.

* * * * *

(f) * * *

(2) * * *

(i) * * *

(D) Divisions 4.1 (self-reactive), 4.2 (spontaneously combustible) (primary or subsidiary risk), and 4.3 (dangerous when wet) (liquids);

* * * * *

§173.124 Class 4, Divisions 4.1, 4.2 and 4.3— Definitions.

(a) * * *

(4) * * *

(iv) The provisions concerning polymerizing substances in paragraph (a)(4) will be effective until January 2, 2023.

* * * * *

§173.137 Class 8—Assignment of packing group.

The packing group of a Class 8 material is indicated in Column 5 of the §172.101 Table. When the §172.101 Table provides more than one packing group for a Class 8 material, the packing group must be determined using data obtained from tests conducted in accordance with the OECD Guidelines for the Testing of Chemicals, Test No. 435, “ In Vitro Membrane Barrier Test Method for Skin Corrosion” (IBR, see §171.7 of this subchapter) or Test No. 404, “Acute Dermal Irritation/Corrosion” (IBR, see §171.7 of this subchapter). A material that is determined not to be corrosive in accordance with OECD Guideline for the Testing of Chemicals, Test No. 430, “ In Vitro Skin Corrosion: Transcutaneous Electrical Resistance Test (TER)” (IBR, see §171.7 of this subchapter) or Test No. 431, “ In Vitro Skin Corrosion: Reconstructed Human Epidermis (RHE) Test Method” (IBR, see §171.7 of this subchapter) may be considered not to be corrosive to human skin for the purposes of this subchapter without further testing. However, a material determined to be corrosive in accordance with Test No. 430 must be further tested using Test No. 435 or Test No. 404. If the in vitro test results indicate that the substance or mixture is corrosive, but the test method does not clearly distinguish between assignment of packing groups II and III, the material may be considered to be in packing group II without further testing. The packing group assignment using data obtained from tests conducted in accordance with OECD Guideline Test No. 404 or Test No. 435 must be as follows:

* * * * *

§173.151 Exceptions for Class 4.

* * * * *

(d) Limited quantities of Division 4.3. Limited quantities of dangerous when wet solids (Division 4.3) in Packing Groups II and III are excepted from labeling requirements, unless the material is offered for transportation or transported by aircraft, and are excepted from the specification packaging requirements of this subchapter when packaged in combination packagings according to this paragraph. For transportation by aircraft, the package must also conform to applicable requirements of §173.27 of this part (e.g., authorized materials, inner packaging quantity limits and closure securement) and only hazardous material authorized aboard passenger-carrying aircraft may be transported as a limited quantity. A limited quantity package that conforms to the provisions of this section is not subject to the shipping paper requirements of subpart C of part 172 of this subchapter, unless the material meets the definition of a hazardous substance, hazardous waste, marine pollutant, or is offered for transportation and transported by aircraft or vessel. In addition, shipments of limited quantities are not subject to subpart F (Placarding) of part 172 of this subchapter. Each package must conform to the packaging requirements of subpart B of this part and may not exceed 30 kg (66 pounds) gross weight. Except for transportation by aircraft, the following combination packagings are authorized:

* * * * *

§173.167 Consumer commodities.

(a) Effective January 1, 2013, a “consumer commodity” (see §171.8 of this subchapter) when offered for transportation by aircraft may only include articles or substances of Class 2 (non-toxic aerosols only), Class 3 (Packing Group II and III only), Division 6.1 (Packing Group III only), UN3077, UN3082, UN3175, UN3334, and UN3335, provided such materials do not have a subsidiary risk and are authorized aboard a passenger-carrying aircraft. Consumer commodities are excepted from the specification outer packaging requirements of this subchapter. Packages prepared under the requirements of this section are excepted from labeling and shipping papers when transported by highway or rail. Except as indicated in §173.24(i), each completed package must conform to §§173.24 and 173.24a of this subchapter. Additionally, except for the pressure differential requirements in §173.27(c), the requirements of §173.27 do not apply to packages prepared in accordance with this section. Packages prepared under the requirements of this section may be offered for transportation and transported by all modes. As applicable, the following apply:

(1) Inner and outer packaging quantity limits. (i) Non-toxic aerosols, as defined in §171.8 of this subchapter and constructed in accordance with §173.306 of this part, in non-refillable, non-metal containers not exceeding 120 mL (4 fluid ounces) each, or in non-refillable metal containers not exceeding 820 mL (28 ounces) each, except that flammable aerosols may not exceed 500 mL (16.9 ounces) each;

(ii) Liquids, in inner packagings not exceeding 500 mL (16.9 ounces) each. Liquids must not completely fill an inner packaging at 55°C;

(iii) Solids, in inner packagings not exceeding 500 g (1.0 pounds) each; or

(iv) Any combination thereof not to exceed 30 kg (66 pounds) gross weight as prepared for shipment.

(2) Closures. Friction-type closures must be secured by positive means. The body and closure of any packaging must be constructed so as to be able to adequately resist the effects of temperature and vibration occurring in conditions normally incident to air transportation. The closure device must be so designed that it is unlikely that it can be incorrectly or incompletely closed.

(3) Absorbent material. Inner packagings must be tightly packaged in strong outer packagings. Absorbent and cushioning material must not react dangerously with the contents of inner packagings. Glass or earthenware inner packagings containing liquids of Class 3 or Division 6.1, sufficient absorbent material must be provided to absorb the entire contents of the largest inner packaging contained in the outer packaging. Absorbent material is not required if the glass or earthenware inner packagings are sufficiently protected as packaged for transport that it is unlikely a failure would occur and, if a failure did occur, that it would be unlikely that the contents would leak from the outer packaging.

(4) Drop test capability. Breakable inner packagings (e.g., glass, earthenware, or brittle plastic) must be packaged to prevent failure under conditions normally incident to transport. Packages of consumer commodities as prepared for transport must be capable of withstanding a 1.2 m drop on solid concrete in the position most likely to cause damage. In order to pass the test, the outer packaging must not exhibit any damage liable to affect safety during transport and there must be no leakage from the inner packaging(s).

(5) Stack test capability. Packages of consumer commodities must be capable of withstanding, without failure or leakage of any inner packaging and without any significant reduction in effectiveness, a force applied to the top surface for a duration of 24 hours equivalent to the total weight of identical packages if stacked to a height of 3.0 m (including the test sample).

(b) When offered for transportation by aircraft:

(1) Packages prepared under the requirements of this section are to be marked as a limited quantity in accordance with §172.315(b)(1) and labeled as a Class 9 article or substance, as appropriate, in accordance with subpart E of part 172 of this subchapter; and

(2) Pressure differential capability: Except for UN3082, inner packagings intended to contain liquids must be capable of meeting the pressure differential requirements (75 kPa) prescribed in §173.27(c) of this part. The capability of a packaging to withstand an internal pressure without leakage that produces the specified pressure differential should be determined by successfully testing design samples or prototypes.

§173.185 Lithium cells and batteries.

* * * * *

(a) * * *

(3) Beginning January 1, 2022 each manufacturer and subsequent distributor of lithium cells or batteries manufactured on or after January 1, 2008, must make available a test summary. The test summary must include the following elements:

* * * * *

* * * * *

(ix) Reference to the revised edition of the UN Manual of Tests and Criteria used and to amendments thereto, if any; and

* * * * *

(b) * * *

(3) * * *

(iii) * * *

(A) Be placed in inner packagings that completely enclose the cell or battery, then placed in an outer packaging. The completed package for the cells or batteries must meet the Packing Group II performance requirements as specified in paragraph (b)(3)(ii) of this section; or

(B) Be placed in inner packagings that completely enclose the cell or battery, then placed with equipment in a package that meets the Packing Group II performance requirements as specified in paragraph (b)(3)(ii) of this section.

* * * * *

(4) * * *

(ii) Equipment must be secured to prevent damage caused by shifting within the outer packaging and be packed so as to prevent accidental operation during transport; and

(iii) Any spare lithium cells or batteries packed with the equipment must be packaged in accordance with paragraph (b)(3) of this section.

* * * * *

(5) Lithium batteries that weigh 12 kg (26.5 pounds) or more and have a strong, impact-resistant outer casing may be packed in strong outer packagings; in protective enclosures (for example, in fully enclosed or wooden slatted crates); or on pallets or other handling devices, instead of packages meeting the UN performance packaging requirements in paragraphs (b)(3)(ii) and (iii) of this section. Batteries must be secured to prevent inadvertent shifting, and the terminals may not support the weight of other superimposed elements. Batteries packaged in accordance with this paragraph may be transported by cargo aircraft if approved by the Associate Administrator.

* * * * *

(c) * * *

(3) Lithium battery mark. Each package must display the lithium battery mark except when a package contains only button cell batteries contained in equipment (including circuit boards), or when a consignment contains two packages or fewer where each package contains not more than four lithium cells or two lithium batteries contained in equipment. [Change Notice][Previous Text]

(i) The mark must indicate the UN number: “UN3090” for lithium metal cells or batteries; or “UN3480” for lithium ion cells or batteries. Where the lithium cells or batteries are contained in, or packed with, equipment, the UN number “UN3091” or “UN3481,” as appropriate, must be indicated. Where a package contains lithium cells or batteries assigned to different UN numbers, all applicable UN numbers must be indicated on one or more marks. The package must be of such size that there is adequate space to affix the mark on one side without the mark being folded.



(A) The mark must be in the form of a rectangle or a square with hatched edging. The mark must be not less than 100 mm (3.9 inches) wide by 100 mm (3.9 inches) high and the minimum width of the hatching must be 5 mm (0.2 inches), except marks of 100 mm (3.9 inches) wide by 70 mm (2.8 inches) high may be used on a package containing lithium batteries when the package is too small for the larger mark;

(B) The symbols and letters must be black on white or suitable contrasting background and the hatching must be red;

(C) The “*” must be replaced by the appropriate UN number(s) and the “**” must be replaced by a telephone number for additional information; and

(D) Where dimensions are not specified, all features shall be in approximate proportion to those shown.

(ii) [Reserved]

(iii) When packages are placed in an overpack, the lithium battery mark shall either be clearly visible through the overpack or be reproduced on the outside of the overpack and the overpack shall be marked with the word “OVERPACK”. The lettering of the “OVERPACK” mark shall be at least 12 mm (0.47 inches) high.

(4) Air transportation. (i) For transportation by aircraft, lithium cells and batteries may not exceed the limits in the following Table 1 to paragraph (c)(4)(i). The limits on the maximum number of batteries and maximum net quantity of batteries in the following table may not be combined in the same package. The limits in the following table do not apply to lithium cells and batteries packed with, or contained in, equipment.

Table 1 to Paragraph (c)(4)(i)
Contents Lithium metal cells and/or batteries with a lithium content not more than 0.3 g Lithium metal cells with a lithium content more than 0.3 g but not more than 1 g Lithium metal batteries with a lithium content more than 0.3 g but not more than 2 g Lithium ion cells and/or batteries with a watt-hour rating not more than 2.7 Wh Lithium ion cells with a watt-hour rating more than 2.7 Wh but not more than 20 Wh Lithium ion batteries with a watt-hour rating more than 2.7 Wh but not more than 100 Wh
Maximum number of cells/batteries per package No Limit 8 cells 2 batteries No Limit 8 cells 2 batteries.
Maximum net quantity (mass) per package 2.5 kg n/a n/a 2.5 kg n/a n/a.

(ii) Not more than one package prepared in accordance with paragraph (c)(4)(i) of this section may be placed into an overpack.

(iii) A shipper is not permitted to offer for transport more than one package prepared in accordance with the provisions of paragraph (c)(4)(i) of this section in any single consignment.

(iv) Each shipment with packages required to display the paragraph (c)(3)(i) lithium battery mark must include an indication on the air waybill of compliance with this paragraph (c)(4) (or the applicable ICAO Technical Instructions Packing Instruction), when an air waybill is used.

(v) Packages and overpacks of lithium batteries prepared in accordance with paragraph (c)(4)(i) of this section must be offered to the operator separately from cargo which is not subject to the requirements of this subchapter and must not be loaded into a unit load device before being offered to the operator.

(vi) For lithium batteries packed with, or contained in, equipment, the number of batteries in each package is limited to the minimum number required to power the piece of equipment, plus two spare sets, and the total net quantity (mass) of the lithium cells or batteries in the completed package must not exceed 5 kg. A “set” of cells or batteries is the number of individual cells or batteries that are required to power each piece of equipment.

(vii) Each person who prepares a package for transport containing lithium cells or batteries, including cells or batteries packed with, or contained in, equipment in accordance with the conditions and limitations of this paragraph (c)(4), must receive instruction on these conditions and limitations, corresponding to their functions.

(viii) Lithium cells and batteries must not be packed in the same outer packaging with other hazardous materials. Packages prepared in accordance with paragraph (c)(4)(i) of this section must not be placed into an overpack with packages containing hazardous materials and articles of Class 1 (explosives) other than Division 1.4S, Division 2.1 (flammable gases), Class 3 (flammable liquids), Division 4.1 (flammable solids), or Division 5.1 (oxidizers).

(5) For transportation by aircraft, a package that exceeds the number or quantity (mass) limits in the table shown in paragraph (c)(4)(i) of this section, the overpack limit described in paragraph (c)(4)(ii) of this section, or the consignment limit described in paragraph (c)(4)(iii) of this section is subject to all applicable requirements of this subchapter, except that a package containing no more than 2.5 kg lithium metal cells or batteries or 10 kg lithium ion cells or batteries is not subject to the UN performance packaging requirements in paragraph (b)(3)(ii) of this section when the package displays both the lithium battery mark in paragraph (c)(3)(i) and the Class 9 Lithium Battery label specified in §172.447 of this subchapter. This paragraph does not apply to batteries or cells packed with or contained in equipment.

* * * * *

(e) * * *

(5) Lithium batteries, including lithium batteries contained in equipment, that weigh 12 kg (26.5 pounds) or more and have a strong, impact-resistant outer casing may be packed in strong outer packagings, in protective enclosures (for example, in fully enclosed or wooden slatted crates), or on pallets or other handling devices, instead of packages meeting the UN performance packaging requirements in paragraphs (b)(3)(ii) and (iii) of this section. The battery must be secured to prevent inadvertent shifting, and the terminals may not support the weight of other superimposed elements;

(6) Irrespective of the limit specified in column (9B) of the §172.101 Hazardous Materials Table, the battery or battery assembly prepared for transport in accordance with this paragraph may have a mass exceeding 35 kg gross weight when transported by cargo aircraft;

(7) Batteries or battery assemblies packaged in accordance with this paragraph are not permitted for transportation by passenger-carrying aircraft, and may be transported by cargo aircraft only if approved by the Associate Administrator prior to transportation; and

* * * * *

§173.224 Packaging and control and emergency temperatures for self-reactive materials.

* * * * *

(b) * * *

(4) Packing method. Column 4 specifies the highest packing method which is authorized for the self-reactive material. A packing method corresponding to a smaller package size may be used, but a packing method corresponding to a larger package size may not be used. The Table of Packing Methods in §173.225(d) defines the packing methods. Bulk packagings for Type F self-reactive substances are authorized by §173.225(f) for IBCs and §173.225(h) for bulk packagings other than IBCs. The formulations listed in §173.225(f) for IBCs and in §173.225(g) for portable tanks may also be transported packed in accordance with packing method OP8, with the same control and emergency temperatures, if applicable. Additional bulk packagings are authorized if approved by the Associate Administrator.

* * * * *

Self-Reactive Materials Table
Self-reactive substance


(1)
Identification No.


(2)
Concentra-
tion—(%)


(3)
Packing method


(4)
Control
tempera-
ture— (°C)


(5)
Emer-
gency
tempera-
ture—


(6)
Notes


(7)
Notes:
1. The emergency and control temperatures must be determined in accordance with §173.21(f).
2. With a compatible diluent having a boiling point of not less than 150 °C.
3. Samples may only be offered for transportation under the provisions of paragraph (c)(3) of this section.
4. This entry applies to mixtures of esters of 2-diazo-1-naphthol-4-sulphonic acid and 2-diazo-1-naphthol-5-sulphonic acid.
5. This entry applies to the technical mixture in n-butanol within the specified concentration limits of the (Z) isomer.
Acetone-pyrogallol copolymer 2-diazo-1-naphthol-5-sulphonate 3228 100 OP8
Azodicarbonamide formulation type B, temperature controlled 3232 <100 OP5 1
Azodicarbonamide formulation type C 3224 <100 OP6
Azodicarbonamide formulation type C, temperature controlled 3234 <100 OP6 1
Azodicarbonamide formulation type D 3226 <100 OP7
Azodicarbonamide formulation type D, temperature controlled 3236 <100 OP7 1
2,2′-Azodi(2,4-dimethyl-4-methoxyvaleronitrile) 3236 100 OP7 −5 +5
2,2′-Azodi(2,4-dimethylvaleronitrile) 3236 100 OP7 +10 +15
2,2′-Azodi(ethyl 2-methylpropionate) 3235 100 OP7 +20 +25
1,1-Azodi(hexahydrobenzonitrile) 3226 100 OP7
2,2-Azodi(isobutyronitrile) 3234 100 OP6 +40 +45
2,2′-Azodi(isobutyronitrile) as a water based paste 3224 ≤50 OP6
2,2-Azodi(2-methylbutyronitrile) 3236 100 OP7 +35 +40
Benzene-1,3-disulphonylhydrazide, as a paste 3226 52 OP7
Benzene sulphohydrazide 3226 100 OP7
4-(Benzyl(ethyl)amino)-3-ethoxybenzenediazonium zinc chloride 3226 100 OP7
4-(Benzyl(methyl)amino)-3-ethoxybenzenediazonium zinc chloride 3236 100 OP7 +40 +45
3-Chloro-4-diethylaminobenzenediazonium zinc chloride 3226 100 OP7
2-Diazo-1-Naphthol sulphonic acid ester mixture 3226 <100 OP7 4
2-Diazo-1-Naphthol-4-sulphonyl chloride 3222 100 OP5
2-Diazo-1-Naphthol-5-sulphonyl chloride 3222 100 OP5
2,5-Dibutoxy-4-(4-morpholinyl)-Benzenediazonium, tetrachlorozincate (2:1) 3228 100 OP8
2,5-Diethoxy-4-morpholinobenzenediazonium zinc chloride 3236 67−100 OP7 +35 +40
2,5-Diethoxy-4-morpholinobenzenediazonium zinc chloride 3236 66 OP7 +40 +45
2,5-Diethoxy-4-morpholinobenzenediazonium tetrafluoroborate 3236 100 OP7 +30 +35
2,5-Diethoxy-4-(phenylsulphonyl)benzenediazonium zinc chloride 3236 67 OP7 +40 +45
2,5-Diethoxy-4-(4-morpholinyl)-benzenediazonium sulphate 3226 100 OP7
Diethylene glycol bis(allyl carbonate) + Diisopropylperoxydicarbonate 3237 ≥88 + ≤12 OP8 −10 0
2,5-Dimethoxy-4-(4-methylphenylsulphony)benzenediazonium zinc chloride 3236 79 OP7 +40 +45
4-Dimethylamino-6-(2-dimethylaminoethoxy)toluene-2-diazonium zinc chloride 3236 100 OP7 +40 +45
4-(Dimethylamino)-benzenediazonium trichlorozincate (-1) 3228 100 OP8
N,N′-Dinitroso-N, N′-dimethyl-terephthalamide, as a paste 3224 72 OP6
N,N′-Dinitrosopentamethylenetetramine 3224 82 OP6 2
Diphenyloxide-4,4′-disulphohydrazide 3226 100 OP7
Diphenyloxide-4,4′-disulphonylhydrazide 3226 100 OP7
4-Dipropylaminobenzenediazonium zinc chloride 3226 100 OP7
2-(N,N-Ethoxycarbonylphenylamino)-3-methoxy-4-(N-methyl-N- cyclohexylamino)benzenediazonium zinc chloride 3236 63−92 OP7 +40 +45
2-(N,N-Ethoxycarbonylphenylamino)-3-methoxy-4-(N-methyl-N- cyclohexylamino)benzenediazonium zinc chloride 3236 62 OP7 +35 +40
N-Formyl-2-(nitromethylene)-1,3-perhydrothiazine 3236 100 OP7 +45 +50
2-(2-Hydroxyethoxy)-1-(pyrrolidin-1-yl)benzene-4-diazonium zinc chloride 3236 100 OP7 +45 +50
3-(2-Hydroxyethoxy)-4-(pyrrolidin-1-yl)benzenediazonium zinc chloride 3236 100 OP7 +40 +45
2-(N,N-Methylaminoethylcarbonyl)-4-(3,4-dimethyl-phenylsulphonyl)benzene diazonium zinc chloride 3236 96 OP7 +45 +50
4-Methylbenzenesulphonylhydrazide 3226 100 OP7
3-Methyl-4-(pyrrolidin-1-yl)benzenediazonium tetrafluoroborate 3234 95 OP6 +45 +50
4-Nitrosophenol 3236 100 OP7 +35 +40
Phosphorothioic acid, O-[(cyanophenyl methylene) azanyl] O,O-diethyl ester 3227 82−91 (Z isomer) OP8 5
Self-reactive liquid, sample 3223 OP2 3
Self-reactive liquid, sample, temperature control 3233 OP2 3
Self-reactive solid, sample 3224 OP2 3
Self-reactive solid, sample, temperature control 3234 OP2 3
Sodium 2-diazo-1-naphthol-4-sulphonate 3226 100 OP7
Sodium 2-diazo-1-naphthol-5-sulphonate 3226 100 OP7
Tetramine palladium (II) nitrate 3234 100 OP6 +30 +35

§173.225 Packaging requirements and other provisions for organic peroxides.

* * * * *

(c) * * *

Table 1 to Paragraph (c)—Organic Peroxide Table
Technical name ID No. Concentration (mass %) Diluent (mass %) Water (mass %) Packing method Temperature (°C) Notes
A B I Control Emergency
(1) (2) (3) (4a) (4b) (4c) (5) (6) (7a) (7b) (8)
Acetyl acetone peroxide UN3105 ≤42 ≥48 ≥8 OP7 2
Acetyl acetone peroxide [as a paste] UN3106 ≤32 OP7 21
Acetyl cyclohexanesulfonyl peroxide UN3112 ≤82 ≥12 OP4 −10 0
Acetyl cyclohexanesulfonyl peroxide UN3115 ≤32 ≥68 OP7 −10 0
tert-Amyl hydroperoxide UN3107 ≤88 ≥6 ≥6 OP8
tert-Amyl peroxyacetate UN3105 ≤62 ≥38 OP7
tert-Amyl peroxybenzoate UN3103 ≤100 OP5
tert-Amyl peroxy-2-ethylhexanoate UN3115 ≤100 OP7 +20 +25
tert-Amyl peroxy-2-ethylhexyl carbonate UN3105 ≤100 OP7
tert-Amyl peroxy isopropyl carbonate UN3103 ≤77 ≥23 OP5
tert-Amyl peroxyneodecanoate UN3115 ≤77 ≥23 OP7 0 +10
tert-Amyl peroxyneodecanoate UN3119 ≤47 ≥53 OP8 0 +10
tert-Amyl peroxypivalate UN3113 ≤77 ≥23 OP5 +10 +15
tert-Amyl peroxypivalate UN3119 ≤32 ≥68 OP8 +10 +15
tert-Amyl peroxy-3,5,5-trimethylhexanoate UN3105 ≤100 OP7
tert-Butyl cumyl peroxide UN3109 >42−100 OP8 9
tert-Butyl cumyl peroxide UN3108 ≤52 ≥48 OP8 9
n-Butyl-4,4-di-(tert-butylperoxy)valerate UN3103 >52−100 OP5
n-Butyl-4,4-di-(tert-butylperoxy)valerate UN3108 ≤52 ≥48 OP8
tert-Butyl hydroperoxide UN3103 >79−90 ≥10 OP5 13
tert-Butyl hydroperoxide UN3105 ≤80 ≥20 OP7 4, 13
tert-Butyl hydroperoxide UN3107 ≤79 >14 OP8 13, 16
tert-Butyl hydroperoxide UN3109 ≤72 ≥28 OP8 13
tert-Butyl hydroperoxide [and] Di-tert-butylperoxide UN3103 <82 + >9 ≥7 OP5 13
tert-Butyl monoperoxymaleate UN3102 >52−100 OP5
tert-Butyl monoperoxymaleate UN3103 ≤52 ≥48 OP6
tert-Butyl monoperoxymaleate UN3108 ≤52 ≥48 OP8
tert-Butyl monoperoxymaleate [as a paste] UN3108 ≤52 OP8
tert-Butyl peroxyacetate UN3101 >52−77 ≥23 OP5
tert-Butyl peroxyacetate UN3103 >32−52 ≥48 OP6
tert-Butyl peroxyacetate UN3109 ≤32 ≥68 OP8
tert-Butyl peroxybenzoate UN3103 >77−100 OP5
tert-Butyl peroxybenzoate UN3105 >52−77 ≥23 OP7 1
tert-Butyl peroxybenzoate UN3106 ≤52 ≥48 OP7
tert-Butyl peroxybenzoate UN3109 ≤32 ≥68 OP8
tert-Butyl peroxybutyl fumarate UN3105 ≤52 ≥48 OP7
tert-Butyl peroxycrotonate UN3105 ≤77 ≥23 OP7
tert-Butyl peroxydiethylacetate UN3113 ≤100 OP5 +20 +25
tert-Butyl peroxy-2-ethylhexanoate UN3113 >52−100 OP6 +20 +25
tert-Butyl peroxy-2-ethylhexanoate UN3117 >32−52 ≥48 OP8 +30 +35
tert-Butyl peroxy-2-ethylhexanoate UN3118 ≤52 ≥48 OP8 +20 +25
tert-Butyl peroxy-2-ethylhexanoate UN3119 ≤32 ≥68 OP8 +40 +45
tert-Butyl peroxy-2-ethylhexanoate [and] 2,2-di-(tert-Butylperoxy)butane UN3106 ≤12 + ≤14 ≥14 ≥60 OP7
tert-Butyl peroxy-2-ethylhexanoate [and] 2,2-di-(tert-Butylperoxy)butane UN3115 ≤31 + ≤36 ≥33 OP7 +35 +40
tert-Butyl peroxy-2-ethylhexylcarbonate UN3105 ≤100 OP7
tert-Butyl peroxyisobutyrate UN3111 >52−77 ≥23 OP5 +15 +20
tert-Butyl peroxyisobutyrate UN3115 ≤52 ≥48 OP7 +15 +20
tert-Butylperoxy isopropylcarbonate UN3103 ≤77 ≥23 OP5
1-(2-tert-Butylperoxy isopropyl)-3-isopropenylbenzene UN3105 ≤77 ≥23 OP7
1-(2-tert-Butylperoxy isopropyl)-3-isopropenylbenzene UN3108 ≤42 ≥58 OP8
tert-Butyl peroxy-2-methylbenzoate UN3103 ≤100 OP5
tert-Butyl peroxyneodecanoate UN3115 >77−100 OP7 −5 +5
tert-Butyl peroxyneodecanoate UN3115 ≤77 ≥23 OP7 0 +10
tert-Butyl peroxyneodecanoate [as a stable dispersion in water] UN3119 ≤52 OP8 0 +10
tert-Butyl peroxyneodecanoate [as a stable dispersion in water (frozen)] UN3118 ≤42 OP8 0 +10
tert-Butyl peroxyneodecanoate UN3119 ≤32 ≥68 OP8 0 +10
tert-Butyl peroxyneoheptanoate UN3115 ≤77 ≥23 OP7 0 +10
tert-Butyl peroxyneoheptanoate [as a stable dispersion in water] UN3117 ≤42 OP8 0 +10
tert-Butyl peroxypivalate UN3113 >67−77 ≥23 OP5 0 +10
tert-Butyl peroxypivalate UN3115 >27−67 ≥33 OP7 0 +10
tert-Butyl peroxypivalate UN3119 ≤27 ≥73 OP8 +30 +35
tert-Butylperoxy stearylcarbonate UN3106 ≤100 OP7
tert-Butyl peroxy-3,5,5-trimethylhexanoate UN3105 >37−100 OP7
tert-Butyl peroxy-3,5,5-trimethlyhexanoate UN3106 ≤42 ≥58 OP7
tert-Butyl peroxy-3,5,5-trimethylhexanoate UN3109 ≤37 ≥63 OP8
3-Chloroperoxybenzoic acid UN3102 >57−86 ≥14 OP1
3-Chloroperoxybenzoic acid UN3106 ≤57 ≥3 ≥40 OP7
3-Chloroperoxybenzoic acid UN3106 ≤77 ≥6 ≥17 OP7
Cumyl hydroperoxide UN3107 >90−98 ≤10 OP8 13
Cumyl hydroperoxide UN3109 ≤90 ≥10 OP8 13, 15
Cumyl peroxyneodecanoate UN3115 ≤87 ≥13 OP7 −10 0
Cumyl peroxyneodecanoate UN3115 ≤77 ≥23 OP7 −10 0
Cumyl peroxyneodecanoate [as a stable dispersion in water] UN3119 ≤52 OP8 −10 0
Cumyl peroxyneoheptanoate UN3115 ≤77 ≥23 OP7 −10 0
Cumyl peroxypivalate UN3115 ≤77 ≥23 OP7 −5 +5
Cyclohexanone peroxide(s) UN3104 ≤91 ≥9 OP6 13
Cyclohexanone peroxide(s) UN3105 ≤72 ≥28 OP7 5
Cyclohexanone peroxide(s) [as a paste] UN3106 ≤72 OP7 5, 21
Cyclohexanone peroxide(s) Exempt ≤32 >68 Exempt 29
Diacetone alcohol peroxides UN3115 ≤57 ≥26 ≥8 OP7 +40 +45 5
Diacetyl peroxide UN3115 ≤27 ≥73 OP7 +20 +25 8,13
Di-tert-amyl peroxide UN3107 ≤100 OP8
([3R- (3R, 5aS, 6S, 8aS, 9R, 10R, 12S, 12aR**)]-Decahydro-10-methoxy-3, 6, 9-trimethyl-3, 12-epoxy-12H-pyrano [4, 3- j]-1, 2-benzodioxepin) UN3106 ≤100 OP7
2,2-Di-(tert-amylperoxy)-butane UN3105 ≤57 ≥43 OP7
1,1-Di-(tert-amylperoxy)cyclohexane UN3103 ≤82 ≥18 OP6
Dibenzoyl peroxide UN3102 >52−100 ≤48 OP2 3
Dibenzoyl peroxide UN3102 >77−94 ≥6 OP4 3
Dibenzoyl peroxide UN3104 ≤77 ≥23 OP6
Dibenzoyl peroxide UN3106 ≤62 ≥28 ≥10 OP7
Dibenzoyl peroxide [as a paste] UN3106 >52−62 OP7 21
Dibenzoyl peroxide UN3106 >35−52 ≥48 OP7
Dibenzoyl peroxide UN3107 >36−42 ≥18 ≤40 OP8
Dibenzoyl peroxide [as a paste] UN3108 ≤56.5 ≥15 OP8
Dibenzoyl peroxide [as a paste] UN3108 ≤52 OP8 21
Dibenzoyl peroxide [as a stable dispersion in water] UN3109 ≤42 OP8
Dibenzoyl peroxide Exempt ≤35 ≥65 Exempt 29
Di-(4-tert-butylcyclohexyl)peroxydicarbonate UN3114 ≤100 OP6 +30 +35
Di-(4-tert-butylcyclohexyl)peroxydicarbonate [as a stable dispersion in water] UN3119 ≤42 OP8 +30 +35
Di-(4-tert-butylcyclohexyl)peroxydicarbonate [as a paste] UN3116 ≤42 OP7 +35 +40
Di-tert-butyl peroxide UN3107 >52−100 OP8
Di-tert-butyl peroxide UN3109 ≤52 ≥48 OP8 24
Di-tert-butyl peroxyazelate UN3105 ≤52 ≥48 OP7
2,2-Di-(tert-butylperoxy)butane UN3103 ≤52 ≥48 OP6
1,6-Di-(tert-butylperoxycarbonyloxy)hexane UN3103 ≤72 ≥28 OP5
1,1-Di-(tert-butylperoxy)cyclohexane UN3101 >80−100 OP5
1,1-Di-(tert-butylperoxy)cyclohexane UN3103 >52−80 ≥20 OP5
1,1-Di-(tert-butylperoxy)-cyclohexane UN3103 ≤72 ≥28 OP5 30
1,1-Di-(tert-butylperoxy)cyclohexane UN3105 >42−52 ≥48 OP7
1,1-Di-(tert-butylperoxy)cyclohexane UN3106 ≤42 ≥13 ≥45 OP7
1,1-Di-(tert-butylperoxy)cyclohexane UN3107 ≤27 ≥25 OP8 22
1,1-Di-(tert-butylperoxy)cyclohexane UN3109 ≤42 ≥58 OP8
1,1-Di-(tert-Butylperoxy) cyclohexane UN3109 ≤37 ≥63 OP8
1,1-Di-(tert-butylperoxy)cyclohexane UN3109 ≤25 ≥25 ≥50 OP8
1,1-Di-(tert-butylperoxy)cyclohexane UN3109 ≤13 ≥13 ≥74 OP8
1,1-Di-(tert-butylperoxy)cyclohexane + tert-Butyl peroxy-2-ethylhexanoate UN3105 ≤43 + ≤16 ≥41 OP7
Di-n-butyl peroxydicarbonate UN3115 >27−52 ≥48 OP7 −15 −5
Di-n-butyl peroxydicarbonate UN3117 ≤27 ≥73 OP8 −10 0
Di-n-butyl peroxydicarbonate [as a stable dispersion in water (frozen)] UN3118 ≤42 OP8 −15 −5
Di-sec-butyl peroxydicarbonate UN3113 >52−100 OP4 −20 −10 6
Di-sec-butyl peroxydicarbonate UN3115 ≤52 ≥48 OP7 −15 −5
Di-(tert-butylperoxyisopropyl) benzene(s) UN3106 >42−100 ≤57 OP7 1, 9
Di-(tert-butylperoxyisopropyl) benzene(s) Exempt ≤42 ≥58 Exempt
Di-(tert-butylperoxy)phthalate UN3105 >42−52 ≥48 OP7
Di-(tert-butylperoxy)phthalate [as a paste] UN3106 ≤52 OP7 21
Di-(tert-butylperoxy)phthalate UN3107 ≤42 ≥58 OP8
2,2-Di-(tert-butylperoxy)propane UN3105 ≤52 ≥48 OP7
2,2-Di-(tert-butylperoxy)propane UN3106 ≤42 ≥13 ≥45 OP7
1,1-Di-(tert-butylperoxy)-3,3,5-trimethylcyclohexane UN3101 >90−100 OP5
1,1-Di-(tert-butylperoxy)-3,3,5-trimethylcyclohexane UN3103 >57−90 ≥10 OP5
1,1-Di-(tert-butylperoxy)-3,3,5-trimethylcyclohexane UN3103 ≤77 ≥23 OP5
1,1-Di-(tert-butylperoxy)-3,3,5-trimethylcyclohexane UN3103 ≤90 ≥10 OP5 30
1,1-Di-(tert-butylperoxy)-3,3,5-trimethylcyclohexane UN3110 ≤57 ≥43 OP8
1,1-Di-(tert-butylperoxy)-3,3,5-trimethylcyclohexane UN3107 ≤57 ≥43 OP8
1,1-Di-(tert-butylperoxy)-3,3,5-trimethylcyclohexane UN3107 ≤32 ≥26 ≥42 OP8
Dicetyl peroxydicarbonate UN3120 ≤100 OP8 +30 +35
Dicetyl peroxydicarbonate [as a stable dispersion in water] UN3119 ≤42 OP8 +30 +35
Di-4-chlorobenzoyl peroxide UN3102 ≤77 ≥23 OP5
Di-4-chlorobenzoyl peroxide Exempt ≤32 ≥68 Exempt 29
Di-2,4-dichlorobenzoyl peroxide [as a paste] UN3118 ≤52 OP8 +20 +25
Di-4-chlorobenzoyl peroxide [as a paste] UN3106 ≤52 OP7 21
Dicumyl peroxide UN3110 >52−100 ≤48 OP8 9
Dicumyl peroxide Exempt ≤52 ≥48 Exempt 29
Dicyclohexyl peroxydicarbonate UN3112 >91−100 OP3 +10 +15
Dicyclohexyl peroxydicarbonate UN3114 ≤91 ≥9 OP5 +10 +15
Dicyclohexyl peroxydicarbonate [as a stable dispersion in water] UN3119 ≤42 OP8 +15 +20
Didecanoyl peroxide UN3114 ≤100 OP6 +30 +35
2,2-Di-(4,4-di(tert-butylperoxy)cyclohexyl)propane UN3106 ≤42 ≥58 OP7
2,2-Di-(4,4-di(tert-butylperoxy)cyclohexyl)propane UN3107 ≤22 ≥78 OP8
Di-2,4-dichlorobenzoyl peroxide UN3102 ≤77 ≥23 OP5
Di-2,4-dichlorobenzoyl peroxide [as a paste with silicone oil] UN3106 ≤52 OP7
Di-(2-ethoxyethyl) peroxydicarbonate UN3115 ≤52 ≥48 OP7 −10 0
Di-(2-ethylhexyl) peroxydicarbonate UN3113 >77−100 OP5 −20 −10
Di-(2-ethylhexyl) peroxydicarbonate UN3115 ≤77 ≥23 OP7 −15 −5
Di-(2-ethylhexyl) peroxydicarbonate [as a stable dispersion in water] UN3119 ≤62 OP8 −15 −5
Di-(2-ethylhexyl) peroxydicarbonate [as a stable dispersion in water] UN3119 ≤52 OP8 −15 −5
Di-(2-ethylhexyl) peroxydicarbonate [as a stable dispersion in water (frozen)] UN3120 ≤52 OP8 −15 −5
2,2-Dihydroperoxypropane UN3102 ≤27 ≥73 OP5
Di-(1-hydroxycyclohexyl)peroxide UN3106 ≤100 OP7
Diisobutyryl peroxide UN3111 >32−52 ≥48 OP5 −20 −10
Diisobutyryl peroxide [as a stable dispersion in water] UN3119 ≤42 OP8 −20 −10
Diisobutyryl peroxide UN3115 ≤32 ≥68 OP7 −20 −10
Diisopropylbenzene dihydroperoxie UN3106 ≤82 ≥5 ≥5 OP7 17
Diisopropyl peroxydicarbonate UN3112 >52−100 OP2 −15 −5
Diisopropyl peroxydicarbonate UN3115 ≤52 ≥48 OP7 −20 −10
Diisopropyl peroxydicarbonate UN3115 ≤32 ≥68 OP7 −15 −5
Dilauroyl peroxide UN3106 ≤100 OP7
Dilauroyl peroxide [as a stable dispersion in water] UN3109 ≤42 OP8
Di-(3-methoxybutyl) peroxydicarbonate UN3115 ≤52 ≥48 OP7 −5 +5
Di-(2-methylbenzoyl)peroxide UN3112 ≤87 ≥13 OP5 +30 +35
Di-(4-methylbenzoyl)peroxide [as a paste with silicone oil] UN3106 ≤52 OP7
Di-(3-methylbenzoyl) peroxide + Benzoyl (3-methylbenzoyl) peroxide + Dibenzoyl peroxide UN3115 ≤20 + ≤18 + ≤4 ≥58 OP7 +35 +40
2,5-Dimethyl-2,5-di-(benzoylperoxy)hexane UN3102 >82−100 OP5
2,5-Dimethyl-2,5-di-(benzoylperoxy)hexane UN3106 ≤82 ≥18 OP7
2,5-Dimethyl-2,5-di-(benzoylperoxy)hexane UN3104 ≤82 ≥18 OP5
2,5-Dimethyl-2,5-di-(tert-butylperoxy)hexane UN3103 >90−100 OP5
2,5-Dimethyl-2,5-di-(tert-butylperoxy)hexane UN3105 >52—90 ≥10 OP7
2,5-Dimethyl-2,5-di-(tert-butylperoxy)hexane UN3108 ≤77 ≥23 OP8
2,5-Dimethyl-2,5-di-(tert-butylperoxy)hexane UN3109 ≤52 ≥48 OP8
2,5-Dimethyl-2,5-di-(tert-butylperoxy)hexane [as a paste] UN3108 ≤47 OP8
2,5-Dimethyl-2,5-di-(tert-butylperoxy)hexyne-3 UN3101 >86−100 OP5
2,5-Dimethyl-2,5-di-(tert-butylperoxy)hexyne-3 UN3103 >52−86 ≥14 OP5
2,5-Dimethyl-2,5-di-(tert-butylperoxy)hexyne-3 UN3106 ≤52 ≥48 OP7
2,5-Dimethyl-2,5-di-(2-ethylhexanoylperoxy)hexane UN3113 ≤100 OP5 +20 +25
2,5-Dimethyl-2,5-dihydroperoxyhexane UN3104 ≤82 ≥18 OP6
2,5-Dimethyl-2,5-di-(3,5,5-trimethylhexanoylperoxy)hexane UN3105 ≤77 ≥23 OP7
1,1-Dimethyl-3-hydroxybutylperoxyneoheptanoate UN3117 ≤52 ≥48 OP8 0 +10
Dimyristyl peroxydicarbonate UN3116 ≤100 OP7 +20 +25
Dimyristyl peroxydicarbonate [as a stable dispersion in water] UN3119 ≤42 OP8 +20 +25
Di-(2-neodecanoylperoxyisopropyl)benzene UN3115 ≤52 ≥48 OP7 −10 0
Di-(2-neodecanoyl-peroxyisopropyl) benzene, as stable dispersion in water UN3119 ≤42 OP8 −15 −5
Di-n-nonanoyl peroxide UN3116 ≤100 OP7 0 +10
Di-n-octanoyl peroxide UN3114 ≤100 OP5 +10 +15
Di-(2-phenoxyethyl)peroxydicarbonate UN3102 >85−100 OP5
Di-(2-phenoxyethyl)peroxydicarbonate UN3106 ≤85 ≥15 OP7
Dipropionyl peroxide UN3117 ≤27 ≥73 OP8 +15 +20
Di-n-propyl peroxydicarbonate UN3113 ≤100 OP3 −25 −15
Di-n-propyl peroxydicarbonate UN3113 ≤77 ≥23 OP5 −20 −10
Disuccinic acid peroxide UN3102 >72−100 OP4 18
Disuccinic acid peroxide UN3116 ≤72 ≥28 OP7 +10 +15
Di-(3,5,5-trimethylhexanoyl) peroxide UN3115 >52−82 ≥18 OP7 0 +10
Di-(3,5,5-trimethylhexanoyl)peroxide [as a stable dispersion in water] UN3119 ≤52 OP8 +10 +15
Di-(3,5,5-trimethylhexanoyl) peroxide UN3119 >38−52 ≥48 OP8 +10 +15
Di-(3,5,5-trimethylhexanoyl)peroxide UN3119 ≤38 ≥62 OP8 +20 +25
Ethyl 3,3-di-(tert-amylperoxy)butyrate UN3105 ≤67 ≥33 OP7
Ethyl 3,3-di-(tert-butylperoxy)butyrate UN3103 >77−100 OP5
Ethyl 3,3-di-(tert-butylperoxy)butyrate UN3105 ≤77 ≥23 OP7
Ethyl 3,3-di-(tert-butylperoxy)butyrate UN3106 ≤52 ≥48 OP7
1-(2-ethylhexanoylperoxy)-1,3-Dimethylbutyl peroxypivalate UN3115 ≤52 ≥45 ≥10 OP7 −20 −10
tert-Hexyl peroxyneodecanoate UN3115 ≤71 ≥29 OP7 0 +10
tert-Hexyl peroxypivalate UN3115 ≤72 ≥28 OP7 +10 +15
3-Hydroxy-1,1-dimethylbutyl peroxyneodecanoate UN3115 ≤77 ≥23 OP7 −5 +5
3-Hydroxy-1,1-dimethylbutyl peroxyneodecanoate [as a stable dispersion in water] UN3119 ≤52 OP8 −5 +5
3-Hydroxy-1,1-dimethylbutyl peroxyneodecanoate UN3117 ≤52 ≥48 OP8 −5 +5
Isopropyl sec-butyl peroxydicarbonat + Di-sec-butyl peroxydicarbonate + Di-isopropyl peroxydicarbonate UN3111 ≤52 + ≤28 + ≤22 OP5 −20 −10
Isopropyl sec-butyl peroxydicarbonate + Di-sec-butyl peroxydicarbonate + Di-isopropyl peroxydicarbonate UN3115 ≤32 + ≤15 −18 + ≤12 −15 ≥38 OP7 −20 −10
Isopropylcumyl hydroperoxide UN3109 ≤72 ≥28 OP8 13
p-Menthyl hydroperoxide UN3105 >72−100 OP7 13
p-Menthyl hydroperoxide UN3109 ≤72 ≥28 OP8
Methylcyclohexanone peroxide(s) UN3115 ≤67 ≥33 OP7 +35 +40
Methyl ethyl ketone peroxide(s) UN3101 ≤52 ≥48 OP5 5, 13
Methyl ethyl ketone peroxide(s) UN3105 ≤45 ≥55 OP7 5
Methyl ethyl ketone peroxide(s) UN3107 ≤40 ≥60 OP8 7
Methyl isobutyl ketone peroxide(s) UN3105 ≤62 ≥19 OP7 5, 23
Methyl isopropyl ketone peroxide(s) UN3109 (See remark 31) ≥70 OP8 31
Organic peroxide, liquid, sample UN3103 OP2 12
Organic peroxide, liquid, sample, temperature controlled UN3113 OP2 12
Organic peroxide, solid, sample UN3104 OP2 12
Organic peroxide, solid, sample, temperature controlled UN3114 OP2 12
3,3,5,7,7-Pentamethyl-1,2,4-Trioxepane UN3107 ≤100 OP8
Peroxyacetic acid, type D, stabilized UN3105 ≤43 OP7 13, 20
Peroxyacetic acid, type E, stabilized UN3107 ≤43 OP8 13, 20
Peroxyacetic acid, type F, stabilized UN3109 ≤43 OP8 13, 20, 28
Peroxyacetic acid or peracetic acid [with not more than 7% hydrogen peroxide] UN3107 ≤36 ≥15 OP8 13, 20, 28
Peroxyacetic acid or peracetic acid [with not more than 20% hydrogen peroxide] Exempt ≤6 ≥60 Exempt 28
Peroxyacetic acid or peracetic acid [with not more than 26% hydrogen peroxide] UN3109 ≤17 OP8 13, 20, 28
Peroxylauric acid UN3118 ≤100 OP8 +35 +40
1-Phenylethyl hydroperoxide UN3109 ≤38 ≥62 OP8
Pinanyl hydroperoxide UN3105 >56−100 OP7 13
Pinanyl hydroperoxide UN3109 ≤56 ≥44 OP8
Polyether poly-tert-butylperoxycarbonate UN3107 ≤52 ≥48 OP8
Tetrahydronaphthyl hydroperoxide UN3106 ≤100 OP7
1,1,3,3-Tetramethylbutyl hydroperoxide UN3105 ≤100 OP7
1,1,3,3-Tetramethylbutyl peroxy-2-ethylhexanoate UN3115 ≤100 OP7 +15 +20
1,1,3,3-Tetramethylbutyl peroxyneodecanoate UN3115 ≤72 ≥28 OP7 −5 +5
1,1,3,3-Tetramethylbutyl peroxyneodecanoate [as a stable dispersion in water] UN3119 ≤52 OP8 −5 +5
1,1,3,3-tetramethylbutyl peroxypivalate UN3115 ≤77 ≥23 OP7 0 +10
3,6,9-Triethyl-3,6,9-trimethyl-1,4,7-triperoxonane UN3110 ≤17 ≥18 ≥65 OP8
3,6,9-Triethyl-3,6,9-trimethyl-1,4,7-triperoxonane UN3105 ≤42 ≥58 OP7 26
Notes:
1. For domestic shipments, OP8 is authorized.
2. Available oxygen must be <4.7%.
3. For concentrations <80% OP5 is allowed. For concentrations of at least 80% but <85%, OP4 is allowed. For concentrations of at least 85%, maximum package size is OP2.
4. The diluent may be replaced by di-tert-butyl peroxide.
5. Available oxygen must be ≤9% with or without water.
6. For domestic shipments, OP5 is authorized.
7. Available oxygen must be ≤8.2% with or without water.
8. Only non-metallic packagings are authorized.
9. For domestic shipments this material may be transported under the provisions of paragraph (h)(3)(xii) of this section.
10. [Reserved]
11. [Reserved]
12. Samples may only be offered for transportation under the provisions of paragraph (b)(2) of this section.
13. “Corrosive” subsidiary risk label is required.
14. [Reserved]
15. No “Corrosive” subsidiary risk label is required for concentrations below 80%.
16. With <6% di-tert-butyl peroxide.
17. With ≤8% 1-isopropylhydroperoxy-4-isopropylhydroxybenzene.
18. Addition of water to this organic peroxide will decrease its thermal stability.
19. [Reserved]
20. Mixtures with hydrogen peroxide, water and acid(s).
21. With diluent type A, with or without water.
22. With ≥36% diluent type A by mass, and in addition ethylbenzene.
23. With ≥19% diluent type A by mass, and in addition methyl isobutyl ketone.
24. Diluent type B with boiling point >100 C.
25. No “Corrosive” subsidiary risk label is required for concentrations below 56%.
26. Available oxygen must be ≤7.6%.
27. Formulations derived from distillation of peroxyacetic acid originating from peroxyacetic acid in a concentration of not more than 41% with water, total active oxygen less than or equal to 9.5% (peroxyacetic acid plus hydrogen peroxide).
28. For the purposes of this section, the names “Peroxyacetic acid” and “Peracetic acid” are synonymous.
29. Not subject to the requirements of this subchapter for Division 5.2.
30. Diluent type B with boiling point >130°C (266°F).
31. Available oxygen ≤6.7%.

(d) *****

Table to Paragraph (d): Maximum Quantity per Packaging/Package

* * * * *

(g) * * *

Table to Paragraph (g) —Organic Peroxide Portable Tank Table
UN No. Hazardous material Minimum test pressure (bar) Minimum shell thickness (mm-reference steel) See . . . Bottom opening requirements See . . . Pressure-relief requirements See . . . Filling limits Control temperature Emergency temperature
3109 ORGANIC PEROXIDE, TYPE F, LIQUID
tert-Butyl hydroperoxide, not more than 72% with water.
*Provided that steps have been taken to achieve the safety equivalence of 65% tert-Butyl hydroperoxide and 35% water.
4 §178.274(d)(2) §178.275(d)(3) §178.275(g)(1) Not more than 90% at 59°F (15°C)
* * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * *
Note: 1. “Corrosive” subsidiary risk placard is required.

* * * * *

§173.301b Additional general requirements for shipment of UN pressure receptacles.

* * * * *

(c) * * *

(1) When the use of a valve is prescribed, the valve must conform to the requirements in ISO 10297:2014(E) and ISO 10297:2014/Amd 1:2017 (IBR, see §171.7 of this subchapter). Quick release cylinder valves for specification and type testing must conform to the requirements in ISO 17871:2015(E) (IBR, see §171.7 of this subchapter). Until December 31, 2022, the manufacture of a valve conforming to the requirements in ISO 10297:2014(E) is authorized. Until December 31, 2020, the manufacture of a valve conforming to the requirements in ISO 10297:2006(E) (IBR, see §171.7 of this subchapter) was authorized. Until December 31, 2008, the manufacture of a valve conforming to the requirements in ISO 10297:1999(E) (IBR, see §171.7 of this subchapter) was authorized.

(2) * * *

(ii) By equipping the UN pressure receptacle with a valve cap conforming to the requirements in ISO 11117:2008(E) and Technical Corrigendum 1 (IBR, see §171.7 of this subchapter). Until December 31, 2014, the manufacture of a valve cap conforming to the requirements in ISO 11117:1998(E) (IBR, see §171.7 of this subchapter) was authorized. The cap must have vent-holes of sufficient cross-sectional area to evacuate the gas if leakage occurs at the valve;

(iii) By protecting the valves by shrouds or guards conforming to the requirements in ISO 11117:2008(E) and Technical Corrigendum 1 (IBR; see §171.7 of this subchapter). Until December 31, 2014, the manufacture of a shroud or guard conforming to the requirements in ISO 11117:1998(E) (IBR, see §171.7 of this subchapter) was authorized. For metal hydride storage systems, by protecting the valves in accordance with the requirements in ISO 16111:2008(E) (IBR; see §171.7 of this subchapter).

(iv) By using valves designed and constructed with sufficient inherent strength to withstand damage in accordance with Annex B of ISO 10297:2014(E)/Amd. 1: 2017;

* * * * *

(d) Non-refillable UN pressure receptacles. (1) When the use of a valve is prescribed, the valve must conform to the requirements in ISO 11118:2015(E), (IBR, see §171.7 of this subchapter). Manufacture of valves to ISO 13340:2001(E) is authorized until December 31, 2020;

* * * * *

(f) Hydrogen bearing gases. A steel UN pressure receptacle bearing an ‘‘H’’ mark must be used for hydrogen bearing gases or other embrittling gases that have the potential of causing hydrogen embrittlement.

* * * * *

§173.302c Additional requirements for the shipment of adsorbed gases in UN pressure receptacles.

* * * * *

(k) The filling procedure must be in accordance with Annex A of ISO 11513 (IBR, see §171.7 of this subchapter).

* * * * *

§173.311 Metal hydride storage systems.

The following packing instruction is applicable to transportable UN Metal hydride storage systems (UN3468) with pressure receptacles not exceeding 150 liters (40 gallons) in water capacity and having a maximum developed pressure not exceeding 25 MPa. Metal hydride storage systems must be designed, constructed, initially inspected and tested in accordance with ISO 16111 (IBR, see §171.7 of this subchapter) as authorized under §178.71(m) of this subchapter. Steel pressure receptacles or composite pressure receptacles with steel liners must be marked in accordance with §173.301b(f) of this part which specifies that a steel UN pressure receptacle bearing an “H” mark must be used for hydrogen bearing gases or other gases that may cause hydrogen embrittlement. Requalification intervals must be no more than every five years as specified in §180.207 of this subchapter in accordance with the requalification procedures prescribed in ISO 16111.

§175.10 Exceptions for passengers, crewmembers, and air operators.

(a) This subchapter does not apply to the following hazardous materials when carried by aircraft passengers or crewmembers provided the requirements of §§171.15 and 171.16 (see paragraph (c) of this section) and the requirements of this section are met:

* * * * *

(14) Battery powered heat-producing devices (e.g., battery-operated equipment such as diving lamps and soldering equipment) as checked or carry-on baggage and with the approval of the operator of the aircraft. The heating element, the battery, or other component (e.g., fuse) must be isolated to prevent unintentional activation during transport. Any battery that is removed must be carried in accordance with the provisions for spare batteries in paragraph (a)(18) of this section.

* * * * *

(15) * * *

(v) * * *

(A) Securely attached to the wheelchair or mobility aid;

* * * * *

(vi) * * *

(A) Securely attached to the wheelchair or mobility aid; or

* * * * *

(17) * * *

(ii) * * *

(C) The battery must be securely attached to the mobility aid; and

* * * * *

(18) Except as provided in §173.21 of this subchapter, portable electronic devices (e.g., watches, calculating machines, cameras, cellular phones, laptop and notebook computers, camcorders, medical devices, etc.) containing dry cells or dry batteries (including lithium cells or batteries) and spare dry cells or batteries for these devices, when carried by passengers or crew members for personal use. Portable electronic devices powered by lithium batteries may be carried in either checked or carry-on baggage. When carried in checked baggage, portable electronic devices powered by lithium batteries must be completely switched off (not in sleep or hibernation mode) and protected to prevent unintentional activation or damage. Spare lithium batteries must be carried in carry-on baggage only. Each installed or spare lithium battery must be of a type proven to meet the requirements of each test in the UN Manual of Tests and Criteria, Part III, Sub-section 38.3, and each spare lithium battery must be individually protected so as to prevent short circuits (e.g., by placement in original retail packaging, by otherwise insulating terminals by taping over exposed terminals, or placing each battery in a separate plastic bag or protective pouch). In addition, each installed or spare lithium battery:

* * * * *

(26) Baggage equipped with lithium battery(ies) must be carried as carry-on baggage unless the battery(ies) is removed from the baggage. Removed battery(ies) must be carried in accordance with the provision for spare batteries prescribed in paragraph (a)(18) of this section. The provisions of this paragraph do not apply to baggage equipped with lithium batteries not exceeding:

* * * * *

§175.33 Shipping paper and information to the pilot-in-command.

(a) * * *

(13) * * *

(iii) For UN3480, UN3481, UN3090, and UN3091 prepared in accordance with §173.185(c), except those prepared in accordance with §173.185(c)(4)(vi), are not required to appear on the information to the pilot-in-command.

* * * * *

§178.37 Specification 3AA and 3AAX seamless steel cylinders.

* * * * *

(j) Flattening test. A flattening test must be performed on one cylinder taken at random out of each lot of 200 or less, by placing the cylinder between wedge shaped knife edges having a 60° included angle, rounded to ½-inch radius. The longitudinal axis of the cylinder must be at a 90-degree angle to knife edges during the test. For lots of 30 or less, flattening tests are authorized to be made on a ring at least 8 inches long cut from each cylinder and subjected to the same heat treatment as the finished cylinder. Cylinders may be subjected to a bend test in lieu of the flattening test. Two bend test specimens must be taken in accordance with ISO 9809–1 or ASTM E 290 (IBR, see §171.7 of this subchapter), and must be subjected to the bend test specified therein.

* * * * *

§178.71 Specifications for UN pressure receptacles.

* * * * *

(f) * * *

(4) ISO 21172-1:2015(E) Gas cylinders—Welded steel pressure drums up to 3,000 litres capacity for the transport of gases—Design and construction—Part 1: Capacities up to 1,000 litres (IBR, see §171.7 of this subchapter). Irrespective of section 6.3.3.4 of this standard, welded steel gas pressure drums with dished ends convex to pressure may be used for the transport of corrosive substances provided all applicable additional requirements are met.

(g) Design and construction requirements for UN refillable seamless steel cylinders. In addition to the general requirements of this section, UN refillable seamless steel cylinders must conform to the following ISO standards, as applicable:

(1) ISO 9809-1:2010 Gas cylinders—Refillable seamless steel gas cylinders—Design, construction and testing—Part 1: Quenched and tempered steel cylinders with tensile strength less than 1100 MPa. (IBR, see §171.7 of this subchapter). Until December 31, 2018, the manufacture of a cylinder conforming to the requirements in ISO 9809-1:1999 (IBR, see §171.7 of this subchapter) is authorized.

(2) ISO 9809-2: Gas cylinders—Refillable seamless steel gas cylinders—Design, construction and testing—Part 2: Quenched and tempered steel cylinders with tensile strength greater than or equal to 1100 MPa. (IBR, see §171.7 of this subchapter). Until December 31, 2018, the manufacture of a cylinder conforming to the requirements in ISO 9809-2:2000 (IBR, see §171.7 of this subchapter) is authorized.

(3) ISO 9809-3: Gas cylinders—Refillable seamless steel gas cylinders—Design, construction and testing—Part 3: Normalized steel cylinders. (IBR, see §171.7 of this subchapter). Until December 31, 2018, the manufacture of a cylinder conforming to the requirements in ISO 9809-3:2000 (IBR, see §171.7 of this subchapter) is authorized.

(4) ISO 9809-4:2014(E) (IBR, see §171.7 of this subchapter).

* * * * *

(i) Design and construction requirements for UN non-refillable metal cylinders. In addition to the general requirements of this section, UN non-refillable metal cylinders must conform to ISO 11118:2015(E) Gas cylinders—Non-refillable metallic gas cylinders—Specification and test methods (IBR, see §171.7 of this subchapter). Until December 31, 2020, cylinders conforming to ISO 11118:1999(E) Gas cylinders—Non-refillable metallic gas cylinders—Specification and test methods (IBR, see §171.7 of this subchapter) are authorized.

* * * * *

(k) * * *

(1) * * *

(i) ISO 9809-1:2010 Gas cylinders—Refillable seamless steel gas cylinders—Design, construction and testing—Part 1: Quenched and tempered steel cylinders with tensile strength less than 1100 MPa. Until December 31, 2018, the manufacture of a cylinder conforming to the requirements in ISO 9809-1:1999 (IBR, see §171.7 of this subchapter) is authorized.

(ii) ISO 9809-3: Gas cylinders—Refillable seamless steel gas cylinders—Design, construction and testing—Part 3: Normalized steel cylinders. Until December 31, 2018, the manufacture of a cylinder conforming to the requirements in ISO 9809-3:2000 (IBR, see §171.7 of this subchapter) is authorized.

* * * * *

(m) Design and construction requirements for UN metal hydride storage systems. In addition to the general requirements of this section, metal hydride storage systems must conform to the following ISO standards, as applicable: ISO 16111: Transportable gas storage devices—Hydrogen absorbed in reversible metal hydride (IBR, see §171.7 of this subchapter).

(n) Design and construction requirements for UN cylinders for the transportation of adsorbed gases. In addition to the general requirements of this section, UN cylinders for the transportation of adsorbed gases must conform to the following ISO standards, as applicable: ISO 11513:2011, Gas cylinders—Refillable welded steel cylinders containing materials for sub-atmospheric gas packaging (excluding acetylene)—Design, construction, testing, use and periodic inspection, or ISO 9809-1:2010: Gas cylinders—Refillable seamless steel gas cylinders—Design, construction and testing—Part 1: Quenched and tempered steel cylinders with tensile strength less than 1100 MPa. (IBR, see §171.7 of this subchapter.)

* * * * *

§178.75 Specifications for MEGCs.

* * * * *

(d) * * *

(3) Each pressure receptacle of a MEGC must be of the same design type, seamless steel, or composite, and constructed and tested according to one of the following ISO standards, as appropriate:

(i) ISO 9809-1: Gas cylinders—Refillable seamless steel gas cylinders—Design, construction and testing—Part 1: Quenched and tempered steel cylinders with tensile strength less than 1100 MPa. (IBR, see §171.7 of this subchapter). Until December 31, 2018, the manufacture of a cylinder conforming to the requirements in ISO 9809-1:1999 (IBR, see §171.7 of this subchapter) is authorized;

(ii) ISO 9809-2: Gas cylinders—Refillable seamless steel gas cylinders—Design, construction and testing—Part 2: Quenched and tempered steel cylinders with tensile strength greater than or equal to 1100 MPa. (IBR, see §171.7 of this subchapter). Until December 31, 2018, the manufacture of a cylinder conforming to the requirements in ISO 9809-2:2000 (IBR, see §171.7 of this subchapter) is authorized;

(iii) ISO 9809-3: Gas cylinders—Refillable seamless steel gas cylinders—Design, construction and testing—Part 3: Normalized steel cylinders. (IBR, see §171.7 of this subchapter). Until December 31, 2018, the manufacture of a cylinder conforming to the requirements in ISO 9809-3:2000 (IBR, see §171.7 of this subchapter) is authorized; or

* * * * *

§178.609 Test requirements for packagings for infectious substances.

* * * * *

(d) * * *

(2) Where the samples are in the shape of a drum, three samples must be dropped, one in each of the following orientations:

(i) Diagonally on the top chime, with the center of gravity directly above the point of impact;

(ii) Diagonally on the base chime; and

(iii) Flat on the side.

* * * * *

§178.706 Standards for rigid plastic IBCs.

* * * * *

(c) * * *

(3) No used material other than production residues or regrind from the same manufacturing process may be used in the manufacture of rigid plastic IBCs.

* * * * *

§178.707 Standards for composite IBCs.

* * * * *

(c) * * *

(3) * * *

(iii) No used material other than production residues or regrind from the same manufacturing process may be used in the manufacture of inner receptacles.

* * * * *

§180.207 Requirements for requalification of UN pressure receptacles.

* * * * *

(d) * * *

(3) Dissolved acetylene UN cylinders: Each dissolved acetylene cylinder must be requalified in accordance with ISO 10462:2013(E) (IBR, see §171.7 of this subchapter). A cylinder previously requalified in accordance with the second edition of ISO 10462(E) up until December 31, 2018, may continue to be used until the next required requalification. The porous mass and the shell must be requalified no sooner than 3 years, 6 months, from the date of manufacture. Thereafter, subsequent requalifications of the porous mass and shell must be performed at least once every ten years.

* * * * *

(5) UN cylinders for adsorbed gases: Each UN cylinder for adsorbed gases must be inspected and tested in accordance with §173.302c and ISO 11513:2011 (IBR, see §171.7 of this subchapter).

* * * * *

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Most Recent Highlights In Environmental

2025-05-27T05:00:00Z

Site Announcement: New Homepage Coming Soon!!!

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Title V operating permits: Comply, certify, repeat
2025-05-23T05:00:00Z

Title V operating permits: Comply, certify, repeat

A Title V operating permit is a legally enforceable document with the federal and state air emissions regulations that a facility must meet to operate. One requirement that applies to all Title V permit holders is the annual compliance certification. It answers whether a facility fulfills the permit’s terms and conditions (such as emissions limits, monitoring, recordkeeping, and reporting).

Whether the Environmental Protection Agency (EPA) or a state or local regulatory agency issues the Title V permit, your facility must complete the annual compliance certification.

Discover what your facility needs to comply, certify, and repeat.

What’s required?

Facilities submit annual compliance certifications to the Title V permitting authority, which is usually a state or local regulatory agency (40 CFR 70.6). An EPA Regional Office serves as the permitting authority (71.6) for federally issued permits.

Title V tip:Check the state or local regulations for Title V compliance certification rules. They may require more frequent submissions and additional information.

At a minimum, the annual compliance certification covers two major areas for every permit term or condition:

  • The compliance methods, and
  • The compliance status.

Let’s take a closer look at each element.

Compliance methods

Your facility’s compliance methods are the ways it tracks whether it’s meeting the Title V permit requirements or not. When a term or condition isn’t met (like exceeding an emission limit), it’s known as a deviation.

Compliance methods consist of monitoring, recordkeeping, and reporting:

  • Monitoring includes the procedures, test methods, and equipment used to track compliance data.
  • Recordkeeping covers:
    • The date, place, and time of monitoring;
    • The date when monitoring results were analyzed, the entity that conducted the analysis, the analytical methods used, and the results; and
    • The operating conditions during monitoring.
  • Reporting consists of semiannual monitoring reports and deviation reports (which list the deviation, the applicable permit requirement, the probable cause, and any corrective or preventive actions).

Compliance status

Three questions determine the compliance status of each permit requirement during the covered period:

  • Did the facility comply with the requirement?
  • Was compliance continuous or intermittent?
  • Were any deviations a “possible exception to compliance"?

Intermittent vs. continuous compliance

For each permit term or condition, your facility has intermittent compliance if it doesn’t meet the requirements at any time during the covered period. Your facility achieves continuous compliance only if it:

  • Performs the necessary compliance methods,
  • Has no unexcused deviations, and
  • Records no contrary evidence.

Possible exception to compliance

EPA defines a possible exception to compliance as “any periods during which compliance is required and in which an excursion or exceedance … occurred” (70.6(c)(5)(iii)(C)).

Simply put, a possible exception to compliance is a deviation that occurs when compliance is mandated. If compliance isn’t required or another permit requirement excuses it, the deviation isn’t a possible exception.

How do I submit a compliance certification?

Your facility’s Title V permit provides instructions for how to submit the annual compliance certification, including the required forms and methods (via mail or electronic submission). You can also confirm requirements with your permitting authority. Generally, federally permitted facilities use the Annual Compliance Certification (EPA Form 5900-04).

Title V tip: Electronic submissions may be an option through the Compliance and Emissions Data Reporting Interface (CEDRI) on EPA’s Central Data Exchange. Check with your permitting authority to determine whether you may submit the annual compliance certification electronically via CEDRI.

Annual compliance certification is vital to maintaining your Title V permit. Keep in mind: comply, certify, and repeat.

Key to remember: Facilities with a Title V operating permit must certify compliance with the requirements at least annually.

Compliance guide: Air regulations for emergency generator installation
2025-05-21T05:00:00Z

Compliance guide: Air regulations for emergency generator installation

In today's rapidly evolving energy landscape, businesses are turning to back-up emergency generators to keep operations running smoothly. Several key factors are driving this growing trend:

  • Extreme heat and weather events

Climate change has led to more intense weather like hurricanes, wildfires, and heatwaves. These events put pressure on power grids, causing outages that disrupt business operations. Generators help by providing backup power during unexpected failures.

  • Power demand from AI and data centers

Artificial intelligence (AI) and data centers need a lot of electricity. As these technologies grow, power grids struggle to keep up. Companies use generators to prevent power shortages and keep essential systems running.

  • Grid reliability concerns

Aging infrastructure and unsteady energy supply from renewable sources can make electrical supply unstable. Industries like manufacturing, healthcare, and finance need steady power to avoid costly interruptions. Generators act as a safety net when the grid fails.

Compliance considerations

Backup generators help keep businesses running, but they also impact the environment. Companies must follow air quality regulations to reduce pollution and operate safely.

Air permits

•State agencies usually oversee air permits, but The U.S. Environmental Protection Agency (EPA) has granted many county and city agencies the authority to issue them. For major permits such as New Source Review (NSR) and Title V, federal regulations apply, but state or local governments may still manage the process.

•In some areas, businesses can apply for a general permit or permit-by-rule for emergency generators. These permits are often easier to obtain and take less time to process. Checking air permitting regulations will help determine if this option is available.

•Businesses should find out if they need a pre-construction or construction air permit before setting up an emergency generator. These permits are based on the proposed equipment’s potential to emit (PTE) of criteria pollutants such as NOx, SO2, CO, and CO2 and hazardous air pollutants (HAPs) such as formaldehyde and acrolein, which are emitted during the combustion of fuel. The type(s) of fuel used in the generator, such as diesel, natural gas, gasoline, or propane, will affect the calculated PTE. Read more about construction permits in this ezExplanation: NSR Permits.

(Note: many state and local permitting agencies allow for the use of 500 hours for calculating PTE from an emergency engine, as per EPA’s 2011 Fox Memo, but some agencies still require using 8,760 hours and only accept 500 hours as an enforceable limit defined in a permit.)

•Federal law sets a limit on emergency generators, allowing less than 100 hours of non-emergency use per year. This includes maintenance and testing. Some permits may also restrict the times of day when the generator can be used for non-emergency purposes.

•The permit may require businesses to use the generator according to the manufacturer’s specifications. This is especially important if the business used manufacturer guarantees to calculate PTE.

•Businesses must track fuel use and operating hours to stay within the limits used in emissions calculations. They can do this using fuel records, fuel measuring devices, and hour meters that log the generator’s usage time.

•After getting a construction permit, a facility may need to apply for an operating permit within a year of the generator beginning operation. Some state and local agencies have stricter rules and deadlines. Check out J. J. Keller’s ezExplanation for Operating Permits: Clean Air Act: Operating Permits

EPA emission standards

The EPA enforces strict emissions regulations for stationary engines. Businesses must ensure their generators meet the New Source Performance Standards (NSPS) for compression ignition (40 CFR 60 Subpart IIII) and spark ignition internal combustion engines (ICE) (40 CFR 60 Subpart JJJJ), which can be found here. Additionally, the National Emission Standards for Hazardous Air Pollutants (NESHAP) apply to reciprocating internal combustion engines (RICE). 40 CFR 63 Subpart ZZZZ can be found here.

These rules, depending on the specific type of generator engine, will be required even if a permit is not necessary.

Other Regulations

Keep in mind that using an emergency generator may also involve other factors depending on the type and amount of fuel stored:

•Aboveground Storage Tank (AST) Requirements

•Spill Prevention Control and Countermeasure (SPCC) Plans

•EPCRA Tier II Reporting

Key to remember: When installing an emergency generator, companies must navigate complex air quality regulations to ensure compliance. By selecting the right fuel type and securing necessary permits, businesses can maintain reliable power while minimizing environmental impact.

Expert Insights: Hazardous waste vs. hazardous materials explained
2025-05-16T05:00:00Z

Expert Insights: Hazardous waste vs. hazardous materials explained

Several questions we receive from our customers use the terms “hazardous waste” and “hazardous materials” interchangeably. At a recent event, a few attendees admitted that they didn’t think there was a difference between the two. This is a common point of confusion, and we want to ensure that our readers know the difference. Let’s dive into it!

Hazardous materials

The term hazardous material is defined by the Department of Transportation. It refers to any substance or material that poses an unreasonable risk to health, safety, and property during transportation. Hazardous materials include hazardous substances, hazardous wastes, marine pollutants, and elevated-temperature materials. Essentially, if it’s dangerous and transported, it’s considered a hazardous material.

Hazardous waste

On the other hand, hazardous waste is defined by the Environmental Protection Agency. It refers to contaminated chemicals or by-products that no longer serve their purpose and need to be disposed of. Hazardous wastes are either listed or exhibit characteristics like ignitability, corrosivity, toxicity, or reactivity. It’s essentially waste that poses a danger to health or the environment and requires special handling and disposal.

To put it simply, hazardous material is a broad term that includes various dangerous substances during transportation, while hazardous waste specifically refers to dangerous by-products that need disposal. Understanding these terms is crucial for compliance with environmental and safety regulations.

If you ever find yourself unsure, remember that hazardous materials are about transportation risks, and hazardous wastes are about disposal risks.

EPA further delays PFAS manufacturing report submission period
2025-05-13T05:00:00Z

EPA further delays PFAS manufacturing report submission period

The Environmental Protection Agency (EPA) issued an interim final rule that further delays the submission period for the one-time reporting requirement for manufacturers of per- and polyfluoroalkyl substances (PFAS). It pushes the starting submission period to April 2026.

Under Section 8(a)(7) of the Toxic Substances Control Act (TSCA), EPA requires any business that manufactured (including imported) any PFAS or PFAS-containing article between 2011 and 2022 to submit the report.

What’s the new timeline?

The Section 8(a)(7) PFAS report’s opening submission period was moved from July 11, 2025, to April 13, 2026. Most manufacturers have six months to submit the report. Small manufacturers reporting only as importers of PFAS-containing articles have one year.

TSCA Section 8(a)(7) PFAS report submission period
Most manufacturersApril 13, 2026–October 13, 2026
Small manufacturers reporting solely as PFAS article importersApril 13, 2026–April 13, 2027

About the report

Manufacturers (including importers) covered by the TSCA Section 8(a)(7) PFAS reporting rule (40 CFR Part 705) must provide information about:

  • Chemical identity, uses, and volumes;
  • By-products;
  • Environmental and health effects;
  • Worker exposure; and
  • Disposal.

It’s the second time EPA has postponed the reporting period. In September 2024, the agency moved the beginning submission period from November 2024 to July 2025. This latest interim rule pushes the starting period from July 2025 to April 2026.

Why the delay?

EPA needs more time to prepare the online reporting tool on the Central Data Exchange that businesses will use to submit the data. The agency will conduct tests to ensure that the application can accept submissions and that reporters don’t encounter technical issues.

Key to remember: EPA further delayed TSCA Section 8(a)(7) PFAS reporting. The submission period now begins on April 13, 2026.

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Most Recent Highlights In Transportation

EHS Monthly Round Up - April 2025

EHS Monthly Round Up - April 2025

In this April 2025 roundup video, we'll review the most impactful environmental health and safety news.

Hi everyone! Welcome to the monthly news roundup video, where we’ll review the most impactful environmental health and safety news. Let’s take a look at what’s happened over the last month!

On April 17, OSHA released 2024 injury and illness data. This includes information from more than 370,000 establishments that submitted Form 300A, as well as partial data from more than 732,000 Form 300 and Form 301 records. OSHA provides public access to the data in an effort to identify unsafe conditions and workplace hazards that may lead to occupational injuries and illnesses.

This year’s National Stand-Down to Prevent Struck-by Incidents took place the week of April 21. Struck-by incidents are the second leading cause of death among construction workers and the leading cause of nonfatal injuries in the construction industry. The stand-down emphasized the importance of training and prevention on worksites.

A safety alert from the Mine Safety and Health Administration urges the mining community to implement effective safety and health programs, with a focus on identifying and eliminating health and safety hazards. The alert was issued due to a high number of mining fatalities in the first quarter of 2025.

The Mine Safety and Health Administration temporarily paused its silica enforcement for coal mine operators until August 18, four months from its original compliance date of April 14. Under the agency’s silica rule, mine operators must update their respiratory protection programs. This may require them to obtain additional respirators and sampling devices. The agency says this four-month pause provides time for operators to come into compliance.

And finally, turning to environmental news, EPA updated the process for making data corrections to hazardous waste manifests. Waste handlers must correct errors on the manifest within 30 days of a request from EPA or a state agency. They also must submit corrections electronically.

And finally, EPA streamlined its pesticide registration process. The agency updated its MyPest app and made policy changes regarding how to submit two of its registration forms.

Thanks for tuning in to the monthly news roundup. We’ll see you next month!

Small quantity generators: Ready for RCRA re-notifications?
2025-05-08T05:00:00Z

Small quantity generators: Ready for RCRA re-notifications?

You’ve likely never thought of “staying in touch” as a legal obligation, but that’s exactly what it is for facilities that generate small quantities of hazardous waste. The Environmental Protection Agency (EPA) mandates that small quantity generators (SQGs) give updates on their hazardous waste activities every four years. The next re-notification is right around the corner; it’s due by September 1, 2025.

Here's what SQGs need to know to stay in touch — and in compliance — with EPA.

What’s the re-notification requirement?

The Resource Conservation and Recovery Act (RCRA) enables EPA to control hazardous waste from generation to disposal. The agency keeps tabs on SQGs through the re-notification regulation at 40 CFR 262.18(d). It requires SQGs to re-notify EPA or the state environmental agency of their generator status and activities every four years by submitting the:

  • Notification of RCRA Subtitle C Activities, also known as the Site Identification (ID) Form (EPA Form 8700-12), or
  • State-equivalent form.

How do SQGs re-notify?

Regulated SQGs must submit the Site ID Form. EPA and many states use the myRCRAid module on RCRA Information (RCRAInfo) for re-notifications.

Here’s how to submit the Site ID Form on myRCRAid:

  1. Log in to RCRAInfo.
  2. Click “Create New Submission” on the myRCRAid tab.
  3. Select the reason for submittal as “Obtaining or updating an EPA ID number for on-going regulated activities (Items 10–17) that will continue for a period of time."
  4. Review and update the information about your site as needed, including the facility’s:
    • EPA ID number,
    • Name and location address,
    • Mailing address,
    • Land type,
    • North American Industry Classification System (or NAICS) code,
    • Site contact information,
    • Legal owner/operator information,
    • Type of regulated waste activity,
    • Additional regulated waste activities, and
    • Status as:
      • An academic entity with laboratories,
      • An episodic generator,
      • A large quantity generator (LQG) consolidating very small quantity generator hazardous waste,
      • An LQG site closing a Central Accumulation Area or facility,
      • A secondary hazardous material manager, and
      • A contractor of an electronic manifest broker.
  5. Include any additional information in the comments section (Item 18).
  6. Click “Review.” Make any needed corrections to the information. Once this is complete, myRCRAid will display the Review Source Record page.
  7. Submit the re-notification:
    • If you don’t have Certifier permission, click “Mark Ready for Signature.” The application will save the form in the “In Progress” section on myRCRAid and notify individuals at your facility with Certifier and Site Manager permissions. The status will display “Ready for Signature."
    • If you have Certifier permission, confirm that the data is correct and click “Sign & Submit” to electronically sign the submission.

Once you submit the Site ID Form, its status on myRCRAid will display “Pending.” EPA or the state regulator will approve or reject the re-notification submission.

Re-notification recommendations

Consider these tips when preparing your SQG re-notification:

  • Most RCRA programs are implemented at the state level. Confirm the re-notification regulations with your state environmental agency. It may not use myRCRAid and may require more frequent submissions.
  • Ensure you have the necessary RCRAInfo permissions to submit the SQG re-notification. A Preparer can enter information into the Site ID form, but only a Certifier or Site Manager with Certifier permission may sign and submit it.
  • EPA accepts submission of the Site ID form at any time within the four years before the next re-notification deadline, so you can submit the re-notification before September 1. Verify with your state whether the same allowance applies.

Submitting the SQG re-notification properly keeps EPA updated and your facility compliant.

Key to remember: Small quantity generators of hazardous waste must re-notify EPA or the state agency by September 1, 2025.

UST release detection equipment: Testing 1, 2, 3
2025-04-24T05:00:00Z

UST release detection equipment: Testing 1, 2, 3

The next time you’re at a service station, consider the fact that you’re standing above underground tanks holding the fuel that you’re pumping into your vehicle. This brings up an important question about any underground tank: Since you can’t see the tank, how do you know if it starts to leak? The answer is a release detection system.

The Environmental Protection Agency (EPA) requires that all regulated underground storage tanks (USTs) have release detection systems and that owners and operators of USTs test the equipment annually to ensure it operates correctly.

Let’s look at three aspects of release detection equipment testing: how to conduct testing, what to test for, and what to record.

1. How do I test the equipment?

UST owners and operators may conduct release detection equipment testing according to:

  • The manufacturer’s instructions,
  • Industry codes and standards, or
  • The implementing agency’s requirements.

Manufacturer’s instructions

Each piece of release detection equipment should have an associated manual or guide for owners to reference. The manual or guide will explain how to test the equipment.

Tip: Most equipment manufacturers provide online versions of their product manuals and guides, which you can likely find on the manufacturer’s website. If you can’t find guidance, contact the manufacturer directly.

Industry codes and standards

EPA’s regulations stipulate that UST owners and operators who follow industry codes and standards must choose ones developed by a nationally recognized association (like ASTM International or the Petroleum Equipment Institute (PEI)) or an independent testing laboratory.

For instance, the agency states at 280.40(a)(3) that UST owners and operators may use PEI/RP1200, Recommended Practices for the Testing and Verification of Spill, Overfill, Leak Detection and Secondary Containment Equipment at UST Facilities, to comply.

Implementing agency requirements

EPA’s rules for testing release detection equipment serve as the minimum standards. Most state regulatory agencies implement UST programs and may impose stricter or additional requirements. Plus, local regulations may apply.

Check state and local rules to ensure your UST complies with the right requirements.

2. What do I test?

At a minimum, UST owners and operators must test the following factors that apply to their release detection systems.

  • Automatic tank gauges and other controllers: Test the alarms and battery backups. Verify the system’s configuration.
  • Probes and sensors: Test alarm functionality and communication with the controller. Inspect the probes and sensors for residual buildup. Ensure that the floats move freely, the cables have no kinks or breaks, and the shaft isn’t damaged.
  • Automatic line leak detectors: Simulate a leak to determine whether the detector meets the operation requirements of 280.44(a).
  • Vacuum pumps and pressure gauges: Confirm correct communication with the sensors and controller.
  • Handheld electronic groundwater and vapor sampling equipment: Ensure the monitoring equipment operates properly.

3. What records do I have to keep?

The regulation at 280.45(b)(1) mandates that UST owners and operators keep records of the annual release detection equipment testing results for at least three years.

For each annual testing record, list:

  • Each device tested,
  • If the devices operated according to 280.40(a)(3) or had issues that needed attention, and
  • Any corrective actions applied.

Why is release detection equipment testing so important?

Petroleum and other hazardous substances that leak from USTs can endanger human and environmental health. A leaking UST’s primary threat is groundwater contamination. Groundwater supplies drinking water for almost half of Americans.

A release detection system enables a facility to respond sooner to accidental releases and, therefore, limit potential harmful impacts — only if the equipment used for the system operates properly.

Testing your UST’s release detection equipment is vital because it allows you to identify which components function accurately and which parts have problems that need correction. A well-functioning release detection system can help your facility:

  • Maintain regulatory compliance (and avoid enforcement actions like penalties),
  • Identify opportunities to upgrade existing equipment to improve operational efficiency, and
  • Protect your employees and the community in which your facility operates.

Key to remember: EPA requires facilities to test the release detection equipment used on underground storage tanks each year to make sure it operates properly.

EPA modernizes pesticide registration policy, tweaks tracking app
2025-04-23T05:00:00Z

EPA modernizes pesticide registration policy, tweaks tracking app

Pesticide registrations just became simpler, more modern, and more transparent! EPA recently updated an app and made policy changes regarding how to submit two forms. All these changes result in a streamlined pesticide registration process.

Pesticide registration tracking app

On April 18, EPA made enhancements to its MyPest app, which sources say was initially launched in mid-January. EPA is proud to say that MyPest already boasts over 1,200 registrants. The new app allows registrants of pesticide products to:

  • Monitor the status of their registration submissions in real-time,
  • Drill down to a detailed view of each application, and
  • Communicate directly with EPA staff about registration packages in review.

Updates to MyPest include an enhanced dashboard page. The page offers information about the registrant’s cases and products. More updates are planned later this year.

Policy changes impacting two forms

On April 4, EPA announced in the Federal Register the issuance of Pesticide Registration (PR) Notice 2025-1. The notice itself is dated effective March 27, 2025. Its subject line reads, “Revised Procedures for Citing Data to Support Pesticide Registrations (EPA Forms No. 8570-34 and 8570-35).”

The latest PR notice supersedes PR Notice 98-5, dated June 12, 1998. While the revisions were proposed last June, the agency only finalized them now. According to PR Notice 2025-1:

  • EPA Form 8570-34 — This is the Certification with Respect to Citation of Data. Pesticide registrants use this form to indicate how they will meet their data submission/citation obligations under the law. When a registrant refers to another company’s data, the registrant must certify that:
    • It offered compensation to the original data submitter, or
    • It has the original data submitter’s permission to cite the data.
  • EPA Form 8570-35 — This is the Data Matrix. Pesticide registrants use this form to indicate to whom they made offers of compensation.

The two forms — EPA Forms 8570-34 and 8570-35 — have not been modified. Only policies regarding the submission of the two forms have changed. The agency:

  • Eliminated the instruction to use “paper” submissions;
  • Says registrants should complete and submit the two forms electronically through the Pesticide Submission Portal;
  • Eliminated the instruction that registrants submit two versions of the Data Matrix, i.e., the ‘‘Internal Agency Use Copy’’ and the ‘‘Public File Copy’’; and
  • Requires that registrants submit a single Data Matrix without redactions.

EPA contends that none of the information on Form 8570-35 is confidential. Put another way, none of the information on the Data Matrix is protected from public release. Therefore, the agency claims there is no reason to submit two versions of the form.

According to EPA, entities potentially affected by the policy changes include, but are not limited to:

  • Crop production,
  • Animal production,
  • Food manufacturing, and
  • Pesticide manufacturing.

Efficiencies and transparencies gained

Using electronic reporting for EPA Forms 8570-34 and 8570-35 brings efficient data transmittal, argues EPA. A bonus is that electronic reporting will also reduce errors. That’s because of automated validation tools in the portal. Submitters should experience lower costs and faster review and transmission of data, the agency adds.

In 2024, EPA received a total of 3,309 Data Matrices. Moving from two versions to just one for the Data Matrix form should save registrants and EPA time. Specifically, completing, submitting, and processing the Data Matrix should be quicker. EPA will also experience time savings when providing the public access to the information. Extra steps under the Freedom of Information Act would not be needed.

The MyPest app update is a step forward in efficiency and transparency, concludes EPA. The app enhancements are part of the agency’s overall move toward digital and streamlined processes. EPA projects that the app will improve the timeliness of pesticide registration decisions.

Key to remember

Recent actions streamline the pesticide registration process and make it more transparent. These actions relate to the MyPest app and EPA Forms 8570-34 and 8570-35.

Workplace recycling in 2025: Why it matters now more than ever
2025-04-17T05:00:00Z

Workplace recycling in 2025: Why it matters now more than ever

Think recycling at work is just tossing paper in a blue bin? Think again. In 2025, workplace recycling is being redefined — from a basic office task to a strategic initiative that impacts your company’s bottom line, brand reputation, and environmental footprint.

From cardboard and plastics to e-waste and food scraps, today’s leading businesses are building smarter, circular systems that turn trash into opportunity — one department at a time.

Here are five reasons why recycling matters now more than ever.

1. Environmental responsibility impacts your brand reputation

Sustainability is no longer just a corporate social responsibility (CSR) talking point. It’s a core business differentiator. As a management or EHS leader, you’re often on the frontlines of implementing the visible changes that shape public perception. Recycling programs are a low-barrier, high-impact initiative that sends a clear message to customers, investors, and employees: We walk the talk.

Failing to prioritize environmental responsibility puts your company’s reputation at risk — especially in industries with public visibility or regulatory scrutiny. Forward-thinking competitors are already using circular economy models and zero-waste initiatives to win market share.

Champion a program that reflects your company’s values and positions you as a sustainability leader in your field.

2. Compliance with local, state, and federal regulations

Recycling is no longer a “nice-to-have.” Many jurisdictions now require commercial recycling, especially for packaging waste, e-waste, and food scraps. Increasingly, regulations also demand data transparency, such as tracking waste volumes, diversion rates, and sustainability goals.

Supervisors in environmental and safety roles are responsible for ensuring compliance and minimizing risk. Violations can result in hefty fines, bad press, or loss of contracts.

Stay ahead of compliance trends and implement a recycling program that satisfies current and future requirements while keeping auditreadiness top of mind.

3. Cost savings and operational efficiency

Landfill disposal is becoming more expensive due to tipping fees and transportation costs. By diverting materials through recycling or reuse programs, companies can reduce both their environmental footprint and their operational spend.

In addition, smart material handling and waste segregation can lead to process improvements — less clutter, fewer hauling pickups, and even opportunities to monetize recyclable materials like scrap metal, cardboard, or used electronics.

Use data from your waste audits and vendor reporting to identify high-volume waste streams and optimize for both cost reduction and resource efficiency.

4. Workforce engagement, retention, and culture

Today’s workforce, particularly younger employees, is drawn to employers who align with their values. A clean, green workplace that visibly supports recycling and sustainability reinforces a positive culture, boosts morale, and improves engagement — especially when employees feel like they’re contributing to something bigger.

Recycling initiatives are also an easy win for cross-departmental engagement. Whether through green teams, signage campaigns, or employee challenges, these programs offer hands-on ways to involve everyone.

Build internal buy-in by showing how your initiatives support company values, employee wellness, and sustainability goals through shared responsibility.

5. Alignment with data-driven ESG and sustainability goals

In 2025, companies are under increasing pressure from stakeholders to report measurable progress on environmental, social, and governance (ESG) initiatives. Waste reduction, recycling rates, and landfill diversion metrics are among the top data points requested in annual sustainability reports and RFPs.

Supervisors and EHS leaders are often the owners of the data. You're tasked with tracking, verifying, and reporting on these outcomes. Without a structured recycling program in place, those metrics are impossible to capture, and your ESG report falls flat.

Establish a system for measuring, improving, and communicating progress toward zero-waste or landfill diversion targets, and support leadership in meeting ESG benchmarks.

Key to remember: Embracing workplace recycling in 2025 isn’t just good for the planet — it’s a smart move that drives innovation, saves money, and positions your company as a leader in sustainability.

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Most Recent Highlights In Safety & Health

EHS Monthly Round Up - March 2025

EHS Monthly Round Up - March 2025

In this March 2025 roundup video, we'll review the most impactful environmental health and safety news.

Hi everyone! Welcome to the monthly news roundup video, where we’ll review the most impactful environmental health and safety news. Let’s get started!

Ladders were the cause of over 22,000 workplace injuries and 161 deaths in 2020. Each March, the American Ladder Institute promotes ladder safety awareness with the goal of reducing ladder-related injuries and fatalities. Every Step Matters was the theme of this year’s National Ladder Safety Month.

Stand Up 4 Grain Safety Week kicked off on March 24. This annual event brings attention to preventable grain handling hazards and promotes safety in this high-hazard industry.

Federal agencies must review their regulations and report back to the White House by April 20. The priority is on “significant” rules, generally considered to be those with an annual effect on the economy of 100 million dollars or more. Once the regulations have been identified, the Office of Management and Budget and the Department of Government Efficiency will work with agency leaders to create a plan for rescinding or modifying the regulations and begin winding down their enforcement.

A highwall fatality at a surface mine prompted the Mine Safety and Health Administration to issue a safety alert. It outlines what miners should do to prevent similar incidents, including looking for hazards such as loose rocks and overhangs before beginning work.

The American Society of Safety Professionals revised its construction training standard. It outlines training requirements for new hires in construction and demolition operations, site procedures, regulatory compliance, and more.

And finally, turning to environmental news, EPA will reconsider a number of major rulemakings that may impact a variety of industries. This is in response to an executive order that federal agencies review their regulations. Among the rules under consideration include those related to clean power, oil and gas emission limits, greenhouse gas reporting, and risk management.

EPA’s Waste Emissions Charge on petroleum and natural gas facilities with high methane emissions is no longer in effect. The rule initially took effect in January and was then disapproved by Congress on March 14.

Thanks for tuning in to the monthly news roundup. We’ll see you next month!

Hazardous waste manifest errors? Follow RCRA’s correction process
2025-04-04T05:00:00Z

Hazardous waste manifest errors? Follow RCRA’s correction process

Hazardous waste manifests are like travel logs. They track the entire journey of regulated hazardous waste, from the starting point (the generator’s facility) to the final destination (the off-site waste management facility). Like travel logs, a manifest is only as accurate as the information provided. Thankfully, you can correct manifest errors.

The Environmental Protection Agency (EPA) finalized the Third Rule under the Resource Conservation and Recovery Act (RCRA), which took effect in January 2025. It made noteworthy changes to the manifest corrections process. Here’s what hazardous waste generators, transporters, and treatment, storage, and disposal facilities (TSDFs) need to know.

Who’s impacted?

The Third Rule impacts entities subject to RCRA’s manifest regulations. This article focuses on the manifest correction rules that apply to these waste handlers:

  • Small and large quantity generators,
  • Transporters, and
  • TSDFs.

Note that the final rule amends post-manifest correction regulations for other entities, such as exporters, that are beyond the scope of this article.

What are the Third Rule changes?

EPA’s final rule maintains most of the post-receipt manifest data corrections process.

What’s the same?

Specifically:

  • Any waste handler named on the manifest may voluntarily submit data corrections at any time,
  • Waste handlers can make an unlimited number of voluntary corrections,
  • Corrections may be applied to an individual record or batch of them, and
  • Submissions must include a signature compliant with the Cross-Media Electronic Reporting Rule (CROMERR).

What’s different?

Previously, when EPA or a state regulatory agency requested corrections to data on a manifest, waste handlers weren’t required to make them. The Third Rule now mandates that waste handlers:

  • Correct errors on the manifest within 30 days of a corrections request from EPA or a state agency, and
  • Make data correction submissions electronically for paper or electronic manifest records.

Post-receipt corrections are made via the Hazardous Waste Electronic Manifest System (e-Manifest) on the RCRA Information (RCRAInfo) system.

The Third Rule also clarifies that receiving facilities (TSDFs) can make corrections only after the manifest is completed (i.e., signed and submitted to the e-Manifest system).

What’s the post-receipt manifest correction process?

Waste handlers submitting voluntary or mandatory post-receipt corrections to hazardous waste manifests must follow the process established at 40 CFR 264.71(l).

Follow this general process on the e-Manifest System:

  • Certify that the manifest is complete. It must have the status “Signed-Completed."
  • Determine how to submit the corrected data to the e-Manifest system. You can enter the data directly into e-Manifest or upload a file with data corrections to the system.
  • Include for each correction submission:
    • The Manifest Tracking Number and date received by the facility associated with the data being corrected,
    • The Item Number(s) of the affected data fields on the manifest form (EPA Form 8700-22), and
    • The previously entered and corrected data.
  • Save your corrections. The manifest’s status will change to “Under Correction."
  • Re-sign the manifest to certify the corrections. The manifest’s status will change to “Corrected."

Manifest correction FAQs

Check out some top questions and answers about post-receipt manifest corrections.

What manifest information can I correct?

The type of waste handler your facility is determines which items on the manifest you can change for voluntary corrections or must change for mandatory corrections. Typically:

  • Generators correct data in Items 1–15;
  • Transporters correct data in Items 6–7, 14, and 17; and
  • TSDFs correct data in Items 14 and 18–20.

What user role do I need on RCRAInfo to submit manifest corrections?

You must be registered in RCRAInfo as a user with the e-Manifest Certifier or Site Manager role for the facility’s site to submit manifest corrections.

What’s the CROMERR certification?

EPA requires manifest correction submitters to use a CROMERR-compliant electronic signature, which requires a higher level of identity proofing than the Quick Sign signature.

Can I revert to a previous manifest version?

Once the corrected manifest has been signed, you can’t revert it to a previous version. The e-Manifest system does, however, let you view all versions of the manifest.

Can brokers sign corrected manifests?

Although brokers can initiate a manifest correction for generators, they may not sign a corrected manifest unless they (a) operate at the generator’s facility and (b) can sign the manifest as an offeror of the waste shipment.

Key to remember: EPA’s Third Rule updates the process for making data corrections to RCRA hazardous waste manifests.

The cost of cutting corners: What a toxic fire teaches us about waste management
2025-04-01T05:00:00Z

The cost of cutting corners: What a toxic fire teaches us about waste management

Are you storing and disposing of hazardous waste correctly or sitting on disaster? Hazardous waste storage is not just a regulatory headache – it is a time bomb for the environment and your company’s bottom line. A disaster in east London, England, is an ongoing issue for nearby residents that highlights the importance of hazardous waste management and why employers must take it seriously.

What happened?

Originally intended for construction waste disposal, the site eventually turned into a dumping ground for hazardous industrial materials. Investigations found plastics, asbestos, industrial chemicals, and carcinogenic substances illegally dumped, creating an environmental and public health hazard. These materials fuel the fires, continuously releasing toxic smoke into the air. Residents have reported respiratory problems, skin irritation, and other health issues while authorities struggle to contain the situation. Even though this incident occurred in London, we can learn plenty of valuable lessons from the incident. Here’s how employers can take proactive measures to ensure compliance, protect workers, and prevent environmental harm:

1. Implement a robust hazardous waste management plan

A hazardous waste management plan should:

  • Include waste classifications (reactive, corrosive, etc.) and an inventory of all hazardous materials used and generated.
  • Ensure all storage and handling procedures, including labeling, segregation of incompatible waste, spill prevention, and containment measures, are followed.
  • Document all waste accumulation and disposal methods. Specify the storage time limits for waste and the methods used for its disposal, such as incineration, recycling, or third-party handling.
  • Provide information on personal protective equipment (PPE) requirements, emergency contact information, reporting procedures, and an evacuation plan in case of a spill.

2. Train employees on hazardous waste handling

Train personnel on their roles and responsibilities when handling hazardous waste. Training should include:

  • Initial and refresher training that complies with the Resource Conservation and Recovery Act (RCRA) and state laws.
  • Identifying unsafe practices and reporting potential violations.

3. Conduct routine inspections and audits

  • Perform internal audits to ensure compliance with RCRA regulations.
  • Schedule third-party audits to identify risks and areas of improvement.
  • Create a corrective action plan for any violations or inefficiencies discovered during audits.

4. Use licensed and certified waste disposal services

The primary reason behind illegal waste dumping is financial. We all know it is not cheap to dispose of hazardous waste, but waste generators are responsible for their waste from “cradle to grave.”

  • Conduct due diligence to verify disposal methods to prevent third-party illegal dumping.
  • Maintain records of manifest, disposal certificate, and compliance documentation.

5. Secure and label waste properly

  • Labels should include “hazardous waste” clearly visible on the container, generator information, accumulation start date, proper shipping name, and waste identification.
  • Store hazardous waste in compatible containers to prevent leaks or spills.

6. Reduce hazardous waste by using safer alternatives

One of the most effective ways to prevent hazardous waste incidents is to reduce reliance on them in the first place. By switching to safer alternatives, employers can lower their risk of exposure. Industries now offer eco-friendly coatings, adhesives, and cleaning agents that perform well without all the side effects. Safer alternatives also reduce compliance costs by lowering the burdens for hazardous waste disposal.

The disaster near London is a stark reminder of the consequences of negligent hazardous waste management. Businesses that cut corners on waste disposal risk legal penalties and contribute to long-term environmental and public health damage.  

Keys to remember: Employers can protect their workforce, comply with regulations, and prevent environmental disasters by adopting proactive waste management strategies.

Congress disapproves EPA's excess methane fees on oil, gas facilities
2025-03-25T05:00:00Z

Congress disapproves EPA's excess methane fees on oil, gas facilities

A joint Congressional resolution disapproved the 2024 Final Waste Emissions Charge (WEC) Rule on oil and gas facilities with high methane emissions. The Environmental Protection Agency (EPA) announced that the regulation, which initially took effect on January 17, 2025, is now no longer in effect.

Who’s impacted?

The WEC rule applied to facilities in the Petroleum and Natural Gas Systems category that:

  • Report emitting more than 25,000 metric tons of carbon dioxide equivalent per year to the Greenhouse Gas Reporting Program (or GHGRP),
  • Exceed specific waste emissions thresholds, and
  • Qualify for no exemptions.

Facilities that were subject to the rule are no longer required to comply (i.e., submit WEC filings by September 2, 2025).

What’s next?

EPA stated it’s “currently evaluating options and obligations for implementing Clean Air Act Section 136(c–g) and will provide additional information to the regulated community at an appropriate time."

Section 136, added by the Inflation Reduction Act of 2022, mandates that EPA implement a methane reduction incentive program for petroleum and natural gas systems, including imposing and collecting a WEC on methane emissions above waste emissions limits.

The disapproval occurred on March 14, 2025, just two days after the agency announced 31 deregulatory actions it plans to take.

Key to remember: EPA’s Waste Emissions Charge on petroleum and natural gas facilities for excess methane is no longer in effect.

EPA announces major regulatory reviews, overhauls
2025-03-19T05:00:00Z

EPA announces major regulatory reviews, overhauls

The Environmental Protection Agency (EPA) announced on March 12, 2025, that it’s taking 31 actions to advance President Trump’s Day One executive orders and the new “Powering the Great American Comeback” Initiative. The agency’s actions will likely impact environmental regulations across various industries.

Rules under review

EPA will reconsider an assortment of rulemakings, including:

  • The Clean Power Plan 2.0 (which sets carbon dioxide emission limits on new gas-fired combustion turbines and emissions guidelines for existing coal, oil, and gas-fired steam generating units),
  • Oil and gas emission limits for new and existing sources (40 CFR Part 60 Subparts OOOOb and OOOOc),
  • The Greenhouse Gas (GHG) Reporting Program (GHGRP) for petroleum and natural gas systems (Part 98 Subpart W),
  • The GHGRP overall (Part 98),
  • Mercury Air Toxics Standards for coal- and oil-fired power plants (Part 63 Subpart UUUUU),
  • Effluent limitation guidelines (ELGs) for the steam electric power generating industry (Part 423),
  • Treated wastewater use and discharge for coal-fired power plants (Part 435 Subpart E),
  • The Risk Management Program rule (Part 68),
  • Vehicle GHG rules (including the light-, medium-, and heavy-duty vehicle regulations),
  • The 2009 Endangerment Finding (relied on for seven federal vehicle rules) and related regulations and actions (Chapter I),
  • The Technology Transition Rule for refrigerant systems (Part 84 Subpart B),
  • The National Ambient Air Quality Standards for fine particulate matter (Parts 50, 53, and 58),
  • The National Emission Standards for Hazardous Air Pollutants (Part 63) for:
    • Iron and steel manufacturing,
    • Rubber tire manufacturing,
    • Synthetic organic chemical manufacturing,
    • Commercial sterilizers for medical devices and spices,
    • Lime manufacturing,
    • Coke ovens,
    • Copper smelting, and
    • Taconite ore processing.
  • The Exceptional Events rulemaking related to allowing prescribed fires within State Implementation Plans (Parts 50–51),
  • The Regional Haze Program implementing regulations (51.308), and
  • The Good Neighbor Plan (Parts 52, 75, 78, and 97).

The agency will also take other actions, such as:

  • Working with the U.S. Army Corps of Engineers to finalize the definition of “waters of the United States” related to Clean Water Act permits,
  • Updating enforcement discretion by revising the National Enforcement and Compliance Initiatives, and
  • Prioritizing the coal ash program to expedite state permit reviews and update the coal ash regulations (including amending the Legacy Coal Combustion Residuals Surface Impoundments and CCR Management Units rule).

About EPA’s new initiative

In February 2025, the agency announced the Powering the Great American Comeback Initiative, which outlines EPA’s priorities. The initiative consists of five pillars:

  • Clean air, land, and water;
  • Restore energy dominance;
  • Permitting reforms, cooperative federalism, and cross-agency partnership;
  • Make the U.S. the artificial intelligence capital of the world; and
  • Protect and bring back American auto jobs.

EPA’s 31 actions will primarily address the first three pillars.

Key to remember: EPA will reconsider major rulemakings that may impact a variety of industries.

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Most Recent Highlights In Human Resources

Lessons from blast: CSB video explores gas detection and emergency plans
2025-03-17T05:00:00Z

Lessons from blast: CSB video explores gas detection and emergency plans

Another riveting video is posted by the Chemical Safety and Hazard Investigation Board (CSB)! The animated video covers a massive explosion at a Texas machine shop. Two workers and a member of the public were killed. Over 450 neighboring homes/businesses were damaged.

Video supports investigative report

The 14-minute video, “No Detection: Explosion …,” follows a June 2023 investigation report. When the 56-page report came out, CSB Chairperson Steve Owens said, “Our investigation found that [the company] did not have an effective program in place to assess potential hazards in its propylene process and did not have a mechanical integrity program or written operating procedures.”

The incident was compounded by emergency planning failures, says CSB. Owens argued, “This tragic incident was made even worse due to the lack of emergency response training for employees at the facility.”

Deadly incident

CSB explains that a degraded and poorly crimped rubber welding hose disconnected from its fitting inside a coating booth. That prompted a release of propylene, a flammable vapor.

By the time workers arrived at the facility the early morning of January 24, 2020, an explosive concentration of propylene had formed inside the building. As workers entered and turned on the lights, the vapor ignited, triggering an explosion. It:

  • Killed two workers,
  • Injured two other workers,
  • Fatally injured a nearby resident, and
  • Damaged hundreds of structures.

The board’s investigation later found that the company had:

  • Disconnected gas detectors from a computer control system. This meant the automatic gas detection shutoff system would not alert operators to a leak. It also would not start up exhaust fans or trigger two shutoff valves to stop the flow of propylene.
  • Replaced a copper tubing connection with a rubber welding hose. Rubber hose is not recommended for propylene. Oils in the gas can cause a rubber hose to form cracks and lose pliability.

OSHA citations before/after the incident

OSHA cited the company 12 years earlier for failing to inspect gas system equipment for signs of deterioration or leaks. The 2008 OSHA visit was prompted by another explosion of propylene gas.

Following the later 2020 incident, OSHA issued citations for failing to:

Safety issues found by CSB

CSB explains that the shop’s propylene amount was below the threshold for OSHA’s Process Safety Management (PSM) standard at 29 CFR 1910.119 or EPA’s Risk Management Plan (RMP) standard at 40 CFR 68. Still, the CSB investigation identified these safety issues:

  • PSM — Had the company had an effective PSM program to identify and control hazards, it could have prevented the incident. Suggested PSM program elements included process safety information, process hazard analysis, management of change, mechanical integrity, and operating procedures.
  • Emergency planning — The company’s emergency response plan did not address responding to a propylene gas leak. The company also failed to train its workers to recognize or respond to a propylene gas release. Hence, workers did not evacuate from the area after suspecting a propylene leak nor contact responders for help.

Owens concludes that the deadly incident could have been mitigated if the company had implemented an effective PSM system for the hazards of its coating operation. Even if a leak occurred, Owens believes an emergency response plan could have prevented the tragic loss of life.

OSHA chemical emergency preparedness may include an emergency action plan and/or an emergency response plan.

Lessons for industry

To prevent chemical incidents, CSB urges you to:

  • Ensure the safety of workers who handle hazardous chemicals (and protect surrounding communities). This is regardless of whether or not the chemicals meet the threshold under PSM and RMP standards.
  • Ensure gas detection, alarm, exhaust, and shutdown systems are adequately designed, maintained, inspected, and tested. The idea is to ensure reliability if your facility handles hazardous chemicals.
  • Ensure a written emergency response plan is implemented. Also, ensure that it adequately addresses all actions to be taken in a release. Workers too need to be trained in the plan and participate in periodic drills.

Have questions about chemical safety or emergency planning? Pose them to our J. J. Keller® experts! Visit our Expert Help page today!

CSB videos are recognized

The latest video comes after the board received a “Silver Play Button” award. The CSB’s video channel boasts 364K subscribers and nearly 100 safety videos. The channel has had over 65M combined views since 2007. What’s more, CSB claims that the chemical industry itself and engineering schools use the videos for chemical safety training.

Key to remember

A new CSB video covers the 2020 massive explosion at a Texas machine shop. The board urges you to implement PSM systems even if not required. CSB also presses you to ensure that workers are trained in emergency response plans.

Expert Insights: A case study in particulate matter control
2025-03-14T05:00:00Z

Expert Insights: A case study in particulate matter control

During a recent discussion about the persistent challenges of maintaining air quality standards within heavy industrial operations, one colleague in the field shared about a large Midwestern industrial facility that faced allegations of significant Clean Air Act violations. Our casual lunch meeting turned into a case study on uncontrolled emissions of particulate matter (PM).

Case details

An investigation identified the facility’s clinker cooler and raw mill operations as primary sources of excess PM. Monitoring data revealed the facility consistently exceeded permitted emission limits, suggesting systemic deficiencies in pollution control systems. Further inspection pointed to potential inadequate maintenance and operation of existing baghouse filters, a critical technology for capturing airborne particles. The facility also appeared to struggle with fugitive dust emissions from material handling and storage areas, indicating a need for improved dust suppression measures.

Proactive management

The case clarifies the importance of rigorous, proactive environmental management within heavy industrial operations. To prevent similar violations, facilities should prioritize comprehensive monitoring and reporting. Continuous emission monitoring systems provide real-time data, enabling early detection of deviations from permitted limits. Regular inspections and preventative maintenance of pollution control equipment are essential. This includes ensuring baghouse filters operate within their design parameters and promptly replacing damaged or worn components.

Additionally, robust fugitive dust control plans are vital. They should address all potential sources of fugitive dust, encompassing material handling, storage, and transport. Implementing strategies such as water spraying, enclosure of conveyors, and optimized material stockpiling can significantly reduce emissions.

Beyond technology

Beyond technology, a strong environmental compliance culture is crucial. It involves employee training on environmental regulations, operational procedures, and the importance of adhering to pollution control measures. Regular audits and internal assessments can help identify potential weaknesses and ensure ongoing compliance.

Industrial facilities can minimize their environmental impact and avoid costly enforcement actions by focusing on:

  • Proactive monitoring,
  • Rigorous maintenance, and
  • A strong compliance culture.
EHS Monthly Round Up - February 2025

EHS Monthly Round Up - February 2025

In this February 2025 roundup video, we'll review the most impactful environmental health and safety news.

Hi everyone! Welcome to the monthly news roundup video, where we’ll review the most impactful environmental health and safety news. There’s a lot going on, so let’s get started!

Under a new Executive Order, federal agencies must eliminate 10 regulations for each new one they introduce. This applies to all new rules, regulations, or guidance issued by government agencies such as the Department of Labor, which includes OSHA, and the Environmental Protection Agency.

A new OSHA fact sheet outlines employee rights and protections when filing a whistleblower complaint. Employers may not retaliate against employees who exercise their rights under the Occupational Safety and Health Act.

OSHA will not cite employers for COVID-19 recordkeeping violations under its Healthcare Emergency Temporary Standard. These regulations are specific to healthcare settings. The provisions remain in effect, but until further notice, OSHA will not enforce them.

New guidance from the National Institute for Occupational Safety and Health recommends that employers use individual, quantitative fit-testing for hearing protection. This helps evaluate how well workers’ hearing protection reduces noise levels and ensures a proper fit.

And finally, turning to environmental news, states across the country continue to consider and implement regulations related to PFAS. These “forever chemicals” are long-lasting chemicals that may pose risks to human and environmental health. A recent study anticipates that more than half of the states in the U.S. are likely to consider PFAS-related policies this year.

Thanks for tuning in to the monthly news roundup. We’ll see you next month!

Ready, set, report! Prepare for EPA’s one-time PFAS report
2025-03-03T06:00:00Z

Ready, set, report! Prepare for EPA’s one-time PFAS report

A group of substances called “forever chemicals” lasts long in the environment, but the submission period for its one-time reporting requirement doesn’t. And it starts in just a few months. The Environmental Protection Agency (EPA) requires covered entities to report data about per- and polyfluoroalkyl substances (PFAS) they manufactured between 2011 and 2022.

Required by Section 8(a)(7) of the Toxic Substances Control Act (TSCA), the report covers PFAS production volumes, disposal, exposures, and hazards. The submission period opens on April 13, 2026. Here are answers to five common questions about the TSCA Section 8(a)(7) report.

Who must report?

The TSCA Section 8(a)(7) reporting requirements apply to any person who manufactured (including imported) a PFAS or PFAS-containing article between January 1, 2011, and December 31, 2022, for commercial purposes.

EPA defines terms for this reporting requirement at 40 CFR 705.3.

One vital thing to note is that the TSCA Section 8(a)(7) reporting requirement allows for no exemptions. The rule even covers PFAS manufactured as a byproduct, impurity, or non-isolated intermediate. The only activity that doesn’t require reporting is importing municipal solid waste streams to dispose of or destroy the waste.

What data does the report cover?

The information required depends on whether you use the standard or streamlined TSCA Section 8(a)(7) reporting form.

The standard form contains:

  • Company and plant site information;
  • Chemical-specific information (such as chemical identities);
  • Categories of use;
  • Total amounts manufactured in each year for each category of use;
  • Byproducts from PFAS manufacturing, processing, use, or disposal;
  • Existing environmental and health effect information;
  • Worker exposure data (including duration); and
  • Disposal methods or processes used (and any changes to them).

The streamlined form requires less information than the standard form. Two types of reporters qualify to use streamlined reporting:

  • Importers of PFAS-containing articles, and
  • Manufacturers of less than 10 kilograms of PFAS used solely for research and development (R&D).

Importers may choose to use the streamlined “PFAS in Imported Article” form. If you imported a PFAS-containing article and manufactured (including imported) the same PFAS (not in an article), you can either:

  • Report the imported article on the streamlined form and the manufactured PFAS on the standard form, or
  • Report both the imported article and the manufactured PFAS on the standard form.

Manufacturers of qualifying R&D PFAS can use the “Research & Development PFAS” form. However, you cannot use the streamlined form if you manufactured a PFAS in small quantities for R&D and otherwise manufactured (including imported) the same PFAS.

When is the report due?

The TSCA Section 8(a)(7) report submission period runs from April 13, 2026, to October 13, 2026, for most manufacturers. Small manufacturers who solely imported PFAS-containing articles have a longer submission period, from April 13, 2026, to April 13, 2027.

Where do I submit the report?

Reports must be submitted electronically through EPA’s Central Data Exchange (CDX). Go to the Chemical Information Submission System and choose the “TSCA Section 8(a)(7)” application.

Note that you must have a registered account on EPA’s CDX to submit the report, and the facility for which you’re submitting the report must also be registered on the platform.

Why is the Section 8(a)(7) report required?

TSCA Section 8(a)(7), as amended by the National Defense Authorization Act for Fiscal Year 2020, required EPA to develop a rule to gather data about PFAS from entities that manufacture or have manufactured PFAS and PFAS-containing articles. The agency finalized the rule in October 2023 for this one-time reporting requirement.

The TSCA Section 8(a)(7) PFAS reports will give EPA a more complete picture of PFAS manufactured in the U.S. The agency will use the data to further its understanding of the forever chemicals and inform future regulatory actions.

Key to remember: The submission period for the one-time PFAS reporting requirement opens April 13, 2026. It applies to anyone who manufactured (including imported) PFAS or PFAS-containing articles between 2011 and 2022.

Used oil disposal: How to stay compliant with EPA, OSHA, and your state
2025-03-03T06:00:00Z

Used oil disposal: How to stay compliant with EPA, OSHA, and your state

Used oil disposal is a critical issue for safety managers and shop supervisors in industrial settings. Whether your facility generates used oil from machinery, vehicles, or hydraulic systems, you must understand the regulatory requirements to ensure compliance and avoid hefty fines.

Used oil is not always considered hazardous waste, but improper handling, storage, or disposal can lead to regulatory violations and environmental hazards. Understanding how used oil is classified, when it is considered hazardous, and how to manage it in compliance with 40 CFR Part 279 is essential.

Let’s uncover the regulatory framework for used oil disposal, including storage requirements, transportation rules, and best practices to ensure compliance at both the federal and state levels.

What is used oil?

The EPA defines used oil as any petroleum-based or synthetic oil that has been used and is contaminated by physical or chemical impurities. Common sources of used oil in industrial operations include:

  • Motor oil and lubricants from vehicle maintenance
  • Hydraulic fluids used in heavy machinery
  • Metalworking fluids and coolants
  • Compressor oils used in air compression systems

According to EPA regulations (40 CFR Part 279), used oil is presumed to be managed under the less stringent used oil management standards unless it meets hazardous waste criteria.

Used oil becomes hazardous waste if:

  • It is mixed with hazardous waste (e.g., solvents or heavy metals)
  • It contains more than 1,000 parts per million (ppm) of total halogens, unless proven otherwise, or
  • It is disposed of improperly, leading to environmental contamination.

If used oil is classified as hazardous waste, it must be managed in accordance with the applicable solid and hazardous waste requirements.

EPA requirements for used oil disposal

The EPA requirements for used oil consist of three different aspects, as outlined below.

1. Storage Requirements

Use leak-proof tanks and containers made of durable, non-earthen materials (e.g., steel, plastic, or concrete). Label all used oil containers with the words "Used Oil" to prevent misidentification. Prevent leaks and spills by using secondary containment systems and regularly inspecting tanks. Never mix used oil with hazardous waste unless authorized.

2. Transportation and Disposal

Used oil generators may transport up to 55 gallons of used oil to a registered collection center without an EPA ID number. If contracting a used oil transporter, ensure they have an EPA Identification Number.

Used oil must be:

  • Recycled or re-refined into new oil.
  • Burned for energy recovery in approved furnaces or boilers.
  • Disposed of at an authorized hazardous waste facility if deemed hazardous.

3. Spill Prevention and Cleanup

Facilities storing large amounts of used oil must have a Spill Prevention, Control, and Countermeasure (SPCC) Plan. SPCC plans establish procedures, methods, and equipment requirements to prevent oil from reaching waterways, and to contain discharges of oil.

Any spills must be cleaned up immediately, and absorbent materials must be disposed of properly. Rags and shop towels contaminated with hazardous materials may be classified as hazardous waste.

OSHA regulations for handling used oil

While the EPA focuses on environmental compliance, OSHA (29 CFR Part 1910) regulates worker safety when handling used oil. Key OSHA requirements include:

1. Personal Protective Equipment (PPE)

Workers handling used oil must wear gloves and protective clothing to prevent skin exposure. Safety goggles or face shields are also important to avoid eye contact.

2. Hazard communication (HazCom) program

Employers must label all used oil containers with appropriate hazard information and train employees on safe handling procedures and emergency response.

3. Fire and Explosion Safety

Always store used oil away from ignition sources to prevent fire hazards. Ensure storage areas are ventilated to avoid vapor buildup.

State-Specific used oil disposal regulations

Many states have stricter used oil regulations than federal laws. For example:

  • California classifies used oil as hazardous waste unless it meets specific recycling criteria.
  • Texas requires additional storage permits for large generators.
  • New York mandates annual reporting on used oil disposal activities.

To ensure compliance, check with your state’s environmental agency for state-specific used oil disposal rules and whether used oil is considered hazardous. Additional permits for transporting or processing used oil may be necessary.

Staying compliant with used oil disposal requirements

Ensuring compliance with EPA, OSHA, and state laws is essential for safety managers and shop supervisors handling used oil. By following proper storage, transportation, and disposal practices, businesses can reduce environmental risks, improve workplace safety, and avoid costly fines.

Key to remember: By staying informed and proactive, your facility can maintain safe, sustainable, and compliant used oil management practices.

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