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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 PHMSA is also withdrawing the unpublished November 28, 2022, Notice of Enforcement Policy Regarding International Standards on the use of select updated international standards in complying with the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

EPA repeals most 2024 Carbon Pollution Standards for fossil fuel-fired power plants
2026-09-17T05:00:00Z

EPA repeals most 2024 Carbon Pollution Standards for fossil fuel-fired power plants

On September 17, 2026, the Environmental Protection Agency (EPA) finalized a rule repealing a majority of the greenhouse gas (GHG) emission requirements established by the 2024 Carbon Pollution Standards (CPS) for fossil fuel-fired power plants. The agency also issued a supplemental proposed rule to rescind all other GHG emission standards for fossil fuel-fired power plants.

Who’s impacted?

EPA’s final rule applies to the fossil fuel-fired electric generating unit (EGU) source category, including:

  • Fossil fuel-fired electric utility steam generating units, and
  • Stationary combustion turbine EGUs.

The final rule specifically impacts:

  • Existing fossil fuel-fired steam generating EGUs (subject to 40 CFR Part 60 Subpart UUUUb),
  • Coal-fired steam generating units conducting a large modification (subject to Part 60 Subpart TTTTa), and
  • New base load stationary combustion turbines (subject to Part 60 Subpart TTTTa).

Final rule: Repeal 2024 CPS regulations

The agency finalized the alternative option from its June 2025 proposed rule, repealing parts of the 2024 CPS and revising the associated best system of emission reduction (BSER) determinations.

EPA’s final rule removes most of the 2024 CPS regulations, including:

  • The emission guidelines for existing coal-, oil-, and natural gas-fired steam generating units (the entirety of Part 60 Subpart UUUUb);
  • The carbon capture and sequestration/storage (CCS)-based standards for coal-fired EGUs conducting a large modification; and
  • The CCS-based standards for new base load stationary combustion turbines (the Phase 2 standards).

The final rule doesn’t repeal or revise the 2024 CPS efficiency-based standards for new stationary combustion turbines (the Phase 1 standards). However, EPA addresses them in the supplemental proposed rule.

Proposed rule: Repeal remaining GHG emission requirements

EPA also issued a supplemental proposed rule to rescind all remaining GHG emission requirements for fossil fuel-fired power plants, including the Phase 1 standards for new stationary combustion turbines. It would require the same regulatory changes as the June 2025 proposed rule but for different reasons.

The supplemental proposed rule would repeal all GHG emission standards in 60 Subparts TTTT and TTTTa for the fossil fuel-fired EGU source category, including the 2015 New Source Performance Standards (NSPS) and the 2024 CPS.

Specifically, EPA would repeal the:

  • Partial CCS-based standards for new and efficiency-based standards for reconstructed or modified steam generating units and integrated gasification combined cycle facilities, and
  • Efficiency-based standards for new or reconstructed stationary combustion turbines.

If the rule is finalized as proposed, fossil fuel-fired EGUs would no longer be required to comply with the GHG emission standards established under the 2015 NSPS or the 2024 CPS regulations.

Key to remember: EPA’s final rule repeals a majority of the greenhouse gas (GHG) emission standards established by the 2024 Carbon Pollution Standards for fossil fuel-fired power plants. The agency also proposes to remove the remaining GHG emission requirements for fossil fuel-fired power plants.

Expert Insights: The hidden compliance risk of employee turnover
2026-09-15T05:00:00Z

Expert Insights: The hidden compliance risk of employee turnover

When environmental professionals think about compliance risks, they often focus on permits, inspections, regulatory changes, and reporting deadlines. Those are certainly important concerns. Yet one of the most significant compliance risks faced by many organizations today has little to do with regulations themselves. It's employee turnover.

Environmental compliance programs depend heavily on institutional knowledge. Over time, employees develop an understanding of permit requirements, reporting schedules, waste streams, inspection practices, agency expectations, and operational nuances that may never be fully captured in a written procedure. When those employees retire, resign, or move into different roles, valuable compliance knowledge can leave with them.

This challenge is becoming more common as organizations experience workforce transitions, retirements, organizational restructuring, and ongoing competition for skilled employees. In some cases, a facility may discover that a single individual has been managing key compliance responsibilities for years with little backup or documentation. Everything may appear to function smoothly until that person is no longer available.

The greatest risks are often not the obvious ones. A permit doesn't disappear when an employee leaves. A reporting deadline doesn't change. Hazardous waste, air emissions, and wastewater obligations continue regardless of who occupies a particular position. The risk arises when important information about those obligations exists primarily in someone's memory rather than within the organization's management system.

Consider a few common examples. An environmental manager may know that a particular production process must be included in annual emissions calculations. A maintenance supervisor may understand why certain inspection frequencies were established. An operations employee may know that a wastewater treatment unit requires additional monitoring during specific production conditions. In some cases, long-term employees have developed productive working relationships with regulatory inspectors and agency staff. They understand how the facility has historically addressed compliance challenges, what information regulators typically request, and the context behind prior inspections or permitting decisions. Experienced personnel often carry these insights with them, yet organizations frequently neglect to capture and document the information for their successors.

Organizations sometimes discover these gaps only after an audit, inspection, or missed deadline. By then, correcting the problem can be far more difficult than preventing it. Fortunately, reducing this risk doesn't necessarily require significant investment. It begins with recognizing that compliance knowledge is an organizational asset rather than an individual asset. Facilities can strengthen resiliency by documenting critical compliance activities, maintaining current procedures, developing training materials, and cross-training employees on key responsibilities. Succession planning shouldn't be limited to leadership positions. It should also include the individuals who perform essential environmental compliance functions.

Environmental management systems can play an important role in this effort. Well-documented processes help ensure that compliance activities continue consistently regardless of changes in personnel. Recordkeeping systems, compliance calendars, written procedures, and periodic reviews all contribute to preserving institutional knowledge and reducing dependence on any single employee.

Every organization experiences personnel changes. The question is whether compliance programs are prepared for them. Facilities that proactively capture knowledge and distribute responsibilities are often better positioned to maintain compliance during periods of transition. In contrast, organizations that rely heavily on individual expertise may discover that employee turnover creates risks they never anticipated.

Environmental compliance is often viewed through the lens of regulations. Increasingly, however, it may be equally important to view compliance through the lens of knowledge management. After all, one of the most valuable environmental assets a facility possesses may be what its employees know and how effectively that knowledge is shared.

Hazardous waste e-Manifest report card: Tips for improving your facility’s manifests
2026-09-14T05:00:00Z

Hazardous waste e-Manifest report card: Tips for improving your facility’s manifests

With the school year fully underway, report cards will soon start to appear. But these performance evaluations aren’t limited to students in the classroom. A recent assessment serves as a “report card” for the federal e-Manifest system, an electronic platform that tracks hazardous waste shipments. And just like a student’s report card, the report reveals areas for improvement.

On August 11, 2026, the Environmental Protection Agency (EPA) Office of Inspector General (OIG) published Evaluation of the EPA’s e-Manifest System. The report identifies the leading errors made by hazardous waste handlers, including:

  • Generators;
  • Transporters; and
  • Treatment, storage, and disposal facilities (TSDFs).

The e-Manifest system’s “report card” offers hazardous waste handlers valuable lessons to help them deliver A+ manifests.

e-Manifest report card results

The OIG analyzed 2022–2024 e-Manifest system data and identified the most frequent errors:

  • Incorrect EPA identification (ID) numbers, and
  • Overstated shipping volumes of hazardous waste.

The report also found that more than 99 percent of manifest submissions between 2019 and 2024 were “data + image” submissions. With this submission type, all hazardous waste handlers use a paper manifest. The TSDF transcribes the data from the paper manifest into an electronic data file and then uploads a scanned image of the final paper manifest and the electronic data file to the e-Manifest system.

The OIG found that most of the errors occurred when TSDFs manually transcribed data from the final paper manifest into the electronic data file.

Incorrect EPA ID numbers

According to the report, about 40 percent of hazardous waste generator EPA ID number entries and 50 percent of TSDF EPA ID number entries were invalid. Many errors were due to entering EPA ID numbers incorrectly, but a notable number of them were connected to very small quantity generators (VSQGs) using paper manifests. VSQGs need an EPA ID number only to use electronic manifests, not paper ones. On paper manifests, VSQGs frequently leave the EPA ID number blank or enter different information to indicate that they don’t have an EPA ID number.

Overstated shipping volumes

Overall, the OIG concluded the most significant errors involved overstated shipping volumes caused by incorrect manifest entries or inaccurate transcriptions of paper manifest data into the e-Manifest system.

Common errors made when copying data from the paper manifests into electronic data files included:

  • Entering incorrect units of measurement (such as using tons for volumes that were calculated in pounds on the paper manifest);
  • Omitting or placing decimal points for volumes in the wrong place (e.g., 941,250 tons instead of 94.1250 tons);
  • Entering data that’s incorrect on the paper manifest; and
  • Duplicating data entries.

Lessons for hazardous waste handlers

Although the OIG’s report was developed for EPA, it offers valuable insights for hazardous waste handlers required to fill out manifests.

Here are some helpful tips gleaned from the report that all hazardous waste handlers can use:

  • Verify that your EPA ID number is entered correctly.
  • Verify that the stated volumes match the units of measurement.
  • Double-check decimal places.
  • If you’re filling out a paper manifest, ensure the information is legible. If you encounter illegible information on a paper manifest, confirm the data with the handler who filled it out.
  • Look for unreasonable information. For example, if the volume on the manifest indicates that thousands of tons (instead of thousands of pounds) of hazardous waste are being shipped, an error likely occurred.

If you don’t have one already, consider developing a checklist for filling out hazardous waste manifests. You can add the tips above and any other parts of your organization’s manifest process to the checklist.

Benefits of electronic manifests

The OIG’s report also emphasizes that electronic manifests offer specific advantages over paper manifests, especially when all hazardous waste handlers use them.

Potential improvements include the following:

  • Increased data accuracy: Because hazardous waste handlers don’t have to copy data from paper manifests into the e-Manifest system, there’s a much lower risk of entering data incorrectly. Plus, electronic manifests solve the issue of illegible entries.
  • Streamlined process: Electronic manifests simplify the data-entry process by removing the need to reenter data from paper manifests into the e-Manifest system.
  • Easier recordkeeping: The e-Manifest system retains all manifest records, so electronic manifest users don’t have to keep paper copies (except for generators that use hybrid manifests).
  • Compliance with possible future regulations: EPA proposed a rule in March 2026 that would require the use of electronic manifests (hybrid or fully electronic) and phase out the use of paper manifests. By shifting to electronic manifests now, hazardous waste handlers would be better prepared to comply with the rule if it’s finalized.

Key to remember: A recent report evaluating EPA’s e-Manifest system offers hazardous waste handlers valuable insights into common manifest errors to avoid.

2026-09-10T05:00:00Z

Virginia adds PFAS requirements to biosolids permit

Effective date: September 23, 2026

This applies to: Owners of sewage treatment works and other biosolids permit holders that land apply, market, or distribute treated sewage sludge (i.e., biosolids)

Description of change: The Virginia State Water Control Board’s revisions to two rules add requirements for per- and polyfluoroalkyl substances (PFAS) to biosolids permits.

Starting January 1, 2027, treatment works must test biosolids for PFAS and report concentrations of perfluorooctanoic acid (PFOA), perfluorooctane sulfonate (PFOS), and all other target analytes to the Department of Environmental Quality (DEQ) and to the entities that apply the biosolids from the treatment works. The requirement also applies to out-of-state sources of biosolids that will be land applied in the state.

Starting July 1, 2027, the DEQ will limit the distribution, marketing, and land application of PFAS-containing biosolids based on concentrations of PFOA and PFOS. Additionally, companies that land apply PFAS-containing biosolids must provide landowners with PFAS monitoring results at least 2 weeks before application.

Starting July 1, 2029, the DEQ will strengthen limits on the distribution, marketing, and land application of PFAS-containing biosolids, basing them on the combined concentrations of PFOA and PFOS.

2026-09-10T05:00:00Z

California updates Landfill Methane Regulation

Effective date: January 1, 2027

This applies to: Owners and operators of municipal solid waste landfills

Description of change: The California Air Resources Board (CARB) updated the Landfill Methane Regulation (LMR). Major amendments include:

  • Requiring inspection and repair when operators are notified of a remotely detected methane emission plume;
  • Making the landfill surface and component leak monitoring procedures more stringent by removing monitoring exemptions, reducing corrective action timelines, and increasing monitoring frequency at certain landfills;
  • Establishing a process to evaluate and approve emerging alternative leak detection technologies and requiring tools (e.g., drone-mounted laser scanners) to identify leaks in inaccessible areas previously excluded from monitoring;
  • Requiring the earlier installation and operation of gas collection infrastructure in new waste deposition areas;
  • Limiting periods of gas collection and control system downtime and mitigating the emissions from unavoidable downtime;
  • Increasing wellhead monitoring parameters and analysis and requiring response actions for out-of-range values and large value changes;
  • Mandating more frequent monitoring, analysis, and mitigation measures (including cover improvements) and requiring more frequent subsurface temperature, oxygen, and liquid level monitoring; and
  • Managing declining gas generation at closed landfills.

The changes to the LMR set stricter requirements than the federal environmental regulations for:

  • Landfill gas collection and control,
  • Component leak testing, and
  • Surface emissions monitoring.
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Most Recent Highlights In Transportation

2026-09-10T05:00:00Z

Tennessee extends air quality construction general permit eligibility

Effective date: November 2, 2026

This applies to: Conditional major sources of emissions

Description of change: The Tennessee Air Pollution Control Board approved amendments granting eligibility for air quality construction general permit coverage to conditional major sources of emissions. The general permit must adequately limit the facility’s potential to emit and include recordkeeping requirements for demonstrating compliance.

Conditional major sources accept federally enforceable permit limitations to avoid obtaining an individual major source operating permit (i.e., complying with the Title V operating permit program).

Related state info: Clean air operating permits state comparison — Tennessee

EHS Monthly Round Up - August 2026

EHS Monthly Round Up - August 2026

In this August 2026 monthly 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 happened over the past month.

Citing elevated injury and illness rates, OSHA relaunched a National Emphasis Program, or NEP, on Warehousing and Distribution Center Operations. Retail operations are no longer targeted by this NEP, as they were previously. Inspectors will focus on common hazards in warehousing and distribution such as powered industrial vehicle operations, materials handling and storage, and fire protection. The NEP also offers OSHA greater discretion in whether to expand an inspection.

OSHA state-plan enforcement continued to gain momentum in fiscal year 2025. In an upward trend, inspection numbers, violation counts, and penalty amounts all increased. The latest data stem from the Occupational Safety and Health Plan Association’s Grassroots Worker Protection report.

OSHA’s Safe+Sound Week was held August 10 through the 16. The event gave employers an opportunity to highlight their safety and health programs and bring attention to common workplace hazards.

The Mine Safety and Health Administration reopened the comment period for proposed changes to the approval criteria for its mine roof control and ventilation plans. The new deadline for comments is September 30.

Turning to environmental news, EPA extended the compliance dates of certain Workplace Chemical Protection Program requirements for perchloroethylene and carbon tetrachloride. The revised deadlines affect facilities subject to the TSCA PCE and CTC risk management rules finalized in 2024.

And finally, EPA published a proposed 2027 general stormwater permit for construction. It applies to construction activities in areas where EPA is the NPDES permitting authority, including Massachusetts, New Hampshire, New Mexico, and the District of Columbia. If finalized, the rule will replace the existing 2022 permit, which expires in early 2027.

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

EPA extends RFS annual compliance report deadline
2026-09-03T05:00:00Z

EPA extends RFS annual compliance report deadline

The Environmental Protection Agency (EPA) issued a prepublication of a final rule extending the Renewable Fuel Standard (RFS) annual compliance reporting deadline for the 2025 compliance year from September 1 to October 1, 2026.

Who’s impacted?

The RFS annual compliance report applies to obligated parties, including:

  • Refiners of gasoline or diesel fuel (transportation fuel), and
  • Importers of transportation fuel.

Under the RFS program, obligated parties with renewable volume obligations (RVOs) must retire enough Renewable Identification Numbers (RINs) to meet their RVOs for the calendar year.

What’s the change?

EPA extended the 2025 RFS compliance reporting deadline to October 1, 2026, giving obligated parties additional time to comply with their 2025 RVOs and submit their annual compliance reports.

Why the change?

EPA recently released its small refinery exemption (SRE) decisions for the 2025 compliance year, exempting 1.76 billion RINs for 29 small refineries. SREs affect the cost and availability of RINs for all obligated parties. The extension gives obligated parties more time to assess the impact of the SRE decisions and adjust their strategies before completing their 2025 RFS reporting obligations.

Key to remember: EPA has extended the Renewable Fuel Standard annual compliance reporting deadline from September 1 to October 1, 2026.

10 operational changes that should trigger an environmental compliance review
2026-09-01T05:00:00Z

10 operational changes that should trigger an environmental compliance review

Environmental compliance issues often arise not because regulations change, but because operations change.

A facility may replace equipment, begin using a new chemical, increase production, or modify a process for legitimate business reasons. However, even routine operational changes can affect permits, reporting obligations, waste generation, emissions, wastewater discharges, or stormwater exposure.

Organizations that review environmental impacts before implementing changes are better positioned to identify compliance obligations early and avoid costly surprises.

What's an environmental compliance review?

An environmental compliance review is a structured evaluation of how a proposed change could affect a facility's environmental obligations.

Many organizations incorporate environmental reviews into an environmental management system (EMS) or formal change-management process. These procedures help ensure that environmental obligations are evaluated before operational changes are implemented. The updated ISO 14001 standard places greater emphasis on managing changes that may affect environmental performance, reinforcing the need to assess environmental impacts before decisions are made.

The review doesn't need to be complicated. In many cases, it involves determining whether the change could affect air permits, wastewater discharges, stormwater permits, hazardous waste management, chemical reporting, spill prevention requirements, or other environmental programs.

The goal is to identify environmental impacts before a change is implemented rather than after a regulator, auditor, or inspector discovers a problem.

Production increases

Increasing production is often viewed as a business decision rather than an environmental one. However, greater production may increase air emissions, wastewater generation, chemical usage, and waste generation.

Facilities should evaluate whether higher throughput could affect permit limits, reporting thresholds, or compliance obligations before production levels increase.

New chemicals or raw materials

A new chemical can trigger a wide range of environmental requirements.

Changes in raw materials may affect hazardous waste determinations, emergency planning requirements, air emissions calculations, Toxics Release Inventory reporting, spill prevention planning, or wastewater characteristics.

Before purchasing or introducing a new chemical, facilities should evaluate its environmental implications and ensure required controls are in place.

Equipment replacements and upgrades

Many organizations assume replacing equipment is simply a maintenance activity. In reality, equipment changes can have environmental consequences.

Replacing a boiler, coating operation, storage tank, dust collector, scrubber, or process equipment may affect emissions, waste streams, monitoring requirements, or permit applicability. Even when equipment serves the same function, environmental impacts should be evaluated before installation.

Process modifications

Changing how a product is manufactured can create environmental consequences even when production levels stay the same.

New process steps, altered operating conditions, different fuels, or modified treatment systems can affect emissions, waste generation, water usage, and permit conditions. Process changes should be reviewed to determine whether existing permits and operating procedures remain appropriate.

Facility expansions

Building additions, new production lines, warehouse expansions, and site development projects often involve environmental considerations beyond construction activities.

Organizations should evaluate potential impacts on air permits, stormwater management, wastewater infrastructure, storage capacity, and environmental monitoring programs before expansion projects begin.

Changes in waste management practices

Facilities occasionally change waste vendors, storage practices, recycling programs, treatment methods, or waste handling procedures to improve efficiency or reduce costs.

While these changes may appear administrative, they can affect generator status, accumulation practices, recordkeeping obligations, and waste determinations. Environmental personnel should review proposed changes before implementation.

New products or services

New products often require new materials, equipment, or processes that may affect existing environmental obligations.

Contractor activities

Contractor activities involving chemicals, waste management, tank cleaning, painting, excavation, demolition, or maintenance may create environmental compliance implications that warrant review.

Property and infrastructure changes

Changes to storage areas, containment systems, drainage patterns, tanks, or utilities can affect stormwater exposure and other environmental obligations.

Acquisitions and ownership changes

Acquiring a facility or business can introduce new permits, reporting obligations, and compliance responsibilities that should be evaluated during due diligence.

Train employees to recognize when a review may be needed

Environmental departments cannot review changes they never hear about.

Engineering, maintenance, operations, purchasing, project management, and production personnel are often the first to learn about proposed changes. Providing basic awareness training can help these groups recognize situations that may have environmental implications.

Employees don't need to become environmental experts. Instead, they should know when to notify EHS and ask whether a compliance review is warranted. A simple "check with EHS before proceeding" expectation can prevent significant compliance problems and reduce the likelihood that environmental requirements will be discovered too late.

Key to remember: Many environmental compliance issues begin with an operational change. Establishing a process to identify and review changes before implementation can help organizations avoid permit problems, reporting errors, and unexpected regulatory obligations.

National wastewater pretreatment program: What type of industrial user is your facility?
2026-08-26T05:00:00Z

National wastewater pretreatment program: What type of industrial user is your facility?

Before the wastewater can flow from your facility into a municipal treatment plant, there’s something you need to know: What type of industrial user is your facility? The answer to this question determines the federal environmental regulations your facility must meet.

The Environmental Protection Agency (EPA) regulates wastewater discharges from industrial and commercial facilities to publicly owned treatment works (POTWs) through the National Pretreatment Program. These facilities, known as industrial users (IUs), must obtain a permit or other control mechanism to send wastewater to a POTW. However, IUs must comply with all applicable federal, state, and local pretreatment requirements, regardless of whether the facility has been issued a permit or other control mechanism.

The National Pretreatment Program applies to:

  • Industrial users (IUs),
  • Significant IUs (SIUs), and
  • Categorical IUs (CIUs).

EPA’s regulations at 40 CFR Part 403 contain compliance requirements for all IUs as well as additional requirements for SIUs and CIUs. To know which regulations to comply with, you must identify the types of IUs that apply to your facility.

Is my facility an IU?

The first type of user is the easiest determination to make. If your industrial or commercial facility discharges wastewater to a POTW, it’s an IU.

Is my facility an SIU?

If your facility can answer “yes” to any of these four questions, it qualifies as an SIU:

  • Is the facility subject to the categorical pretreatment standards under 403.6 and Subchapter N?
  • Does the facility discharge an average of at least 25,000 gallons daily of process wastewater to the POTW (not including sanitary, noncontact cooling, and boiler blowdown wastewater)?
  • Does the facility contribute a process waste stream that makes up at least 5 percent of the POTW’s average dry weather hydraulic or organic capacity?
  • Is your facility designated as an SIU by the control authority (i.e., the POTW, state, or EPA)?

Even if the first three criteria don’t apply, the control authority may designate your facility as an SIU if it determines that there’s a reasonable potential for your facility’s wastewater discharges:

  • To adversely affect the POTW’s operation, or
  • To violate the pretreatment standards.

Limited exceptions allow the control authority to designate a facility as a non-significant CIU (if the facility meets specific conditions according to 403.3(v)(2)) or to determine that the facility has no reasonable potential to harm POTW operations or violate the standards (403.3(v)(3)).

Is my facility a CIU?

The National Pretreatment Program has rules that apply to specific industrial processes, known as categorical pretreatment standards. If your facility is subject to a categorical requirement in Parts 405–471, it’s considered a CIU. Examples of covered categories include:

  • Metal finishing (Part 433);
  • Organic chemical, plastic, and synthetic fiber manufacturing (Part 414); and
  • Petroleum refining (Part 419).

Submit a category determination request

The control authority director determines whether any of the categorical standards apply to a facility through a process called “categorical determination.” IUs may submit a category determination request when a new categorical standard is established that could apply to their existing facility. Additionally, EPA requires IUs to request a determination when:

  • An existing facility adds or changes an operation or process that may make it subject to an existing categorical pretreatment standard, and
  • A facility becomes a new source of discharge to a POTW.

The director will issue a final decision as to whether any of the regulations in Parts 405–471 apply to the facility.

Which pretreatment regulations apply?

The control authority will include the applicable regulations in the facility’s permit or implement the requirements through other control mechanisms. These will be at least as stringent as the following federal standards.

Requirements for all IUs

General and specific prohibitions apply to all types of IUs, banning facilities from discharging pollutants and categories of pollutants that can cause pass through or interference at the POTW.

Additionally, all IUs must report specific discharges and changes to existing discharge practices to the control authority.

Requirements for SIUs

SIUs have additional compliance obligations, such as:

  • Conducting self-monitoring and submitting periodic compliance reports every 6 months for SIUs not subject to categorical standards, and
  • Developing and implementing a slug control plan if required.

Requirements for CIUs

CIUs also have more requirements, including (but not limited to):

  • The applicable categorical pretreatment standards (Parts 405–471),
  • The categorical standards at 403.6, and
  • Additional reporting and notification requirements.

Understanding the types of IUs that characterize your facility can help clarify which federal wastewater rules apply.

Key to remember: The type of industrial user determines the National Pretreatment Program requirements applicable to facilities that discharge wastewater to publicly owned treatment plants.

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Most Recent Highlights In Safety & Health

2026-08-25T05:00:00Z

New Hampshire adopts PFAS product regulations

Effective date: July 17, 2026

This applies to: Any entity that manufactures or supplies specific consumer products with intentionally added per- and polyfluoroalkyl substances (PFAS)

Description of change: The New Hampshire Department of Environmental Services adopted rules to implement the Per- and Polyfluoroalkyl Substances Products Control Program, which bans certain PFAS-added consumer products from being sold, offered for sale, or distributed for sale or promotional purposes.

The regulations:

  • Ban certain products with intentionally added PFAS from being sold or distributed in New Hampshire (unless specifically exempt);
  • Establish the certificate of compliance (COC) process, under which manufacturers and suppliers must provide a COC upon request of the department to demonstrate compliance; and
  • Establish exemptions.

The ban applies to PFAS-added products manufactured on or after January 1, 2027. Product categories include:

  • Carpets and rugs;
  • Cosmetics;
  • Feminine hygiene products;
  • Food packaging and containers;
  • Juvenile products;
  • Textile furnishings;
  • Textile treatments;
  • Upholstered furniture; and
  • Waxes for use on boats; skis; surfboards; bodyboards; and skimboards.

Examples of exempted products include all products manufactured before January 1, 2027; secondhand products; and products with at least 85 percent recycled content.

2026-08-25T05:00:00Z

New Hampshire requires electronic applications for AOT permits

Effective date: August 6, 2026

This applies to: Projects that will disturb more than 100,000 square feet of terrain (or 50,000 square feet if it’s within the protected shoreline) and projects that will disturb any area with a 25 percent or steeper land slope that’s within 50 feet of surface water

Description of change: The New Hampshire Department of Environmental Services amended the regulations for Alteration of Terrain (AOT) permitting, requiring applicants to submit all permit applications and permits by notification online through its new e-permitting system, NHEnviro.

The department also made other changes, such as:

  • Expanding the general permit rule to cover specific steep slope projects, and
  • Exempting excavation and mining projects from the 5-acre open area disturbance limit.
Maintenance and environmental compliance go hand in hand
2026-08-21T05:00:00Z

Maintenance and environmental compliance go hand in hand

Environmental compliance is often viewed as the responsibility of the environmental, health, and safety (EHS) department. In reality, many compliance successes and failures occur on the plant floor, in maintenance shops, and around equipment managed by maintenance personnel.

Maintenance employees regularly handle used oil, inspect tanks, repair air pollution control equipment, respond to spills, and maintain secondary containment systems. Their daily decisions can directly affect compliance with federal, state, and local environmental requirements. As facilities face increased scrutiny of air emissions, waste management, and spill prevention programs, coordination between environmental and maintenance personnel has become increasingly important. That's why one of the most valuable members of an environmental compliance team is often someone from maintenance.

Used oil management starts in the shop

Many maintenance departments generate used oil from equipment servicing, vehicle maintenance, and hydraulic system repairs. While used oil can often be managed under streamlined regulations, improper handling can quickly create compliance problems.

Common issues include storing used oil in unlabeled containers, mixing used oil with hazardous waste, and failing to address leaks from storage containers. Even small mistakes can increase disposal costs or change how the waste must be managed.

Maintenance personnel can help reduce these risks by ensuring used oil containers remain closed when not in use, are properly labeled, and are routinely inspected for signs of leakage or deterioration.

Spill response depends on employees closest to the release

When a spill occurs, maintenance staff members are often among the first employees on scene.

Their actions during the first few minutes can affect both environmental impacts and regulatory obligations. Quickly stopping the source of a release, protecting drains, and containing spilled material can prevent a minor incident from becoming a reportable event.

Facilities should ensure maintenance personnel understand spill response procedures, know where response equipment is located, and recognize when environmental staff or emergency responders must be notified.

Even facilities with formal spill response plans depend on maintenance employees to implement many of the initial response actions.

Air compliance requires reliable equipment

Many facilities rely on air pollution control devices such as baghouses, scrubbers, thermal oxidizers, and dust collection systems to comply with permit requirements.

Environmental managers may be responsible for reporting emissions and maintaining permit records, but maintenance staff members are often responsible for keeping control equipment operating properly.

A failed pressure gauge, malfunctioning fan, broken duct connection, or neglected preventive maintenance task can affect emissions performance and potentially result in permit deviations.

Facilities should ensure maintenance programs include environmental control equipment and that maintenance personnel understand which equipment has environmental significance.

Tanks and containment need routine attention

Storage tanks and secondary containment systems are another area where maintenance and environmental responsibilities overlap.

Maintenance personnel may also maintain stormwater controls, drainage structures, and outdoor storage areas that affect permit compliance.

Routine inspections can identify corrosion, damaged coatings, leaking fittings, deteriorated hoses, and cracks before they become larger problems. These conditions may not seem urgent from an operational perspective, but they can increase the risk of releases and regulatory violations.

Facilities should establish inspection procedures, clearly define responsibilities, and document findings. A simple inspection program can often identify problems early, reducing both environmental risk and repair costs.

Communication helps prevent violations

Many environmental compliance issues occur when operational changes are made without considering environmental impacts.

New equipment, replacement tanks, process modifications, and maintenance projects can affect air emissions, waste generation, chemical storage, and spill prevention requirements. Environmental staff may not become aware of these changes until after installation.

Regular communication between maintenance and environmental personnel can help identify potential compliance concerns before work begins. In many cases, a short conversation during project planning can prevent significant compliance challenges later.

Building a partnership between maintenance and environmental teams

Environmental compliance is most effective when it's integrated into daily operations. Maintenance teams often have the best understanding of equipment conditions, storage systems, and operational changes occurring throughout a facility.

Environmental awareness training, maintenance involvement in inspections, and regular communication can strengthen compliance programs and identify problems sooner.

Environmental managers bring regulatory expertise. Maintenance personnel bring operational knowledge. Together, they create a stronger foundation for compliance than either group can achieve alone.

Key to remember: Environmental compliance isn't solely an EHS responsibility. Maintenance staff members play a critical role in preventing spills, managing used oil, maintaining compliance equipment, and identifying problems before they become violations.

2026-08-14T05:00:00Z

Virginia requires PFAS monitoring for wastewater

Effective date: September 9, 2026

This applies to: Publicly owned treatment works (POTW)

Description of change: The Virginia State Water Control Board adopted amendments to the Virginia Pollutant Discharge Elimination System (VPDES) Permit regulation. The updated regulations:

  • Require POTWs to mandate quarterly discharge monitoring for per- and polyfluoroalkyl substances (PFAS) for certain industrial user categories,
  • Establish a 30-day reporting deadline for monitoring results, and
  • Specify acceptable test methods.

Covered industrial categories include:

  • PFAS manufacturing facilities;
  • Electroplating and metal finishing facilities using PFAS;
  • Semiconductor and circuit board facilities using PFAS;
  • Paper and packaging manufacturing facilities using PFAS;
  • Textile mills and tanneries using PFAS and leather, fabric, and carpet treaters using PFAS;
  • Centralized waste treatment industrial facilities;
  • Industrial launderers; and
  • Any other facility or site that’s a source of PFAS (such as landfills).

The POTWs must report results quarterly to the Virginia Department of Environmental Quality. Additionally, industrial users must report monitoring results within 30 days of receiving the laboratory results.

Related state info: Industrial water permitting — Virginia

2026-08-14T05:00:00Z

Virginia amends water withdrawal reporting requirements

Effective date: September 9, 2026

This applies to: Water users providing water to another person off-site

Description of the change: The Virginia State Water Control Board amended water withdrawal reporting requirements for water users providing water to another person off-site. These users are now required to report monthly (or quarterly if applicable) the total volumes of potable water and reclaimed water that they provided:

  • To a data center with an air permit from the Virginia Department of Environmental Quality; and
  • For domestic, commercial, industrial, and all other non-categorized purposes.

The reporting requirement takes effect on January 1, 2027.

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Most Recent Highlights In Human Resources

TSCA Exposure Control Plan: 5 FAQs answered
2026-08-14T05:00:00Z

TSCA Exposure Control Plan: 5 FAQs answered

Do you have a toxic work environment — literally? For facilities that handle chemicals, the answer is likely yes. And for specific chemicals, federal environmental regulations require facilities to protect workers by controlling their exposure to these substances.

The Workplace Chemical Protection Program (WCPP) is one way the Environmental Protection Agency (EPA) protects potentially exposed workers from hazardous chemicals in the workplace. And at the core of the WCPP is the Exposure Control Plan (ECP); it’s the roadmap documenting how a facility will keep its employees safe. If your business manufactures (including imports), processes, distributes, uses, or disposes of a chemical substance subject to risk management regulations under Section 6 of the Toxic Substances Control Act (TSCA), an ECP may be required.

Consider these FAQs to help you implement an effective ECP that guards your workers against a “toxic work environment."

What’s an ECP?

An ECP is a strategic document explaining:

  • What exposure controls the facility takes to reduce occupational exposure to a regulated chemical to or below EPA’s exposure limits; and
  • How the facility will implement the other WCPP requirements (such as implementing exposure controls, establishing regulated areas, and providing training).

Any time a facility uses a TSCA Section 6 chemical that’s subject to the WCPP regulations (40 CFR Part 751), an ECP is required. This applies even if exposure monitoring determines that the concentration of a regulated chemical substance is below the existing chemical exposure limit or action level.

How do you develop an ECP?

Owners or operators must establish an ECP using the hierarchy of controls framework, following a sequence of actions to identify the control measures that will best reduce hazardous workplace exposures. The hierarchy of controls is ordered from the most to the least effective methods:

  • Elimination stops the use of the chemical.
  • Substitution replaces the chemical with a safer alternative.
  • Engineering controls prevent people from coming into contact with the chemical (e.g., local exhaust ventilation and protective barriers).
  • Administrative controls establish work practices that reduce the duration, frequency, or intensity of chemical exposure (like limiting access to exposure areas).
  • Personal protective equipment (PPE), such as respirators, reduces or mitigates exposure.

EPA requires owners or operators to consider every level of the hierarchy. PPE should be a last resort and used only when other controls aren’t possible or when other methods don’t sufficiently reduce hazardous exposure to safe levels.

What’s in an ECP?

Generally, an ECP must include the following:

  • The exposure control measures that were considered using the hierarchy of controls;
  • The reason why each control measure was selected or not selected based on feasibility, effectiveness, or other relevant information;
  • The actions required to implement the selected controls (e.g., installation, maintenance, training);
  • The regulated areas (workplace locations where worker exposure may exceed exposure limits), how they’re identified, and the people authorized to enter them;
  • The process for reviewing and updating the ECP to ensure that the exposure controls are effective, updated when needed, and properly implemented; and
  • The procedures for responding to new sources of or increases in exposure to the regulated chemical, including taking corrective actions.

Owners or operators must review and update ECPs when making major changes to the WCPP. However, EPA’s chemical-specific rules limit the length of time between reviews. The review frequency in the chemical-specific rule is the minimum requirement.

For example, the perchloroethylene rule (751.607) requires facilities to review and update the ECP at least every 5 years, while the chrysotile asbestos rule (751.511) requires facilities to review and update the ECP at least annually.

Can an ECP be added to an existing safety program?

Yes! Owners or operators can either:

  • Incorporate the ECP into an existing industrial hygiene or chemical management program (like a chemical hygiene plan) if the ECP contains all the required components, or
  • Develop an individual document for the ECP.

Can one ECP be used for multiple regulated chemicals?

EPA allows owners or operators to develop one standalone ECP that covers multiple chemicals subject to TSCA Section 6 regulations if the plan complies with each chemical’s specific requirements.

Key to remember: The Exposure Control Plan explains how a facility will implement the Workplace Chemical Protection Program and the exposure controls needed to protect workers from hazardous chemical exposures.

The environmental compliance program hiding in your chemical inventory
2026-08-13T05:00:00Z

The environmental compliance program hiding in your chemical inventory

Environmental programs may appear unrelated, but most rely on accurate information about the chemicals a facility uses, stores, or generates. Air permits, hazardous waste determinations, emergency planning, chemical reporting, and spill response programs all depend on knowing what chemicals are on site.

Yet chemical inventory management is often divided among multiple departments. Purchasing tracks what comes in, operations tracks what is used, maintenance stores products for later use, and environmental staff may only become involved when reporting deadlines approach. When inventories are incomplete or outdated, compliance problems can quickly follow.

A single source of truth supports multiple programs

Before a facility can determine its environmental obligations, it must first understand what chemicals are present on site.

The information contained in a chemical inventory supports numerous environmental programs, and different inventory data serve different purposes. Product quantities may affect EPCRA reporting. Chemical constituents help identify TRI chemicals and estimate releases. Usage data support air emissions calculations, while information about spent materials can help determine whether hazardous waste rules apply. Storage quantities, container types, and locations may also affect spill prevention and emergency response planning.

Consider a facility that introduces a new solvent for equipment cleaning. Purchasing may view it as a routine substitution, but the environmental implications may be much broader. The solvent may contain volatile organic compounds (VOCs) that affect air permits, TRI-listed constituents, or chemicals subject to EPCRA. If the spent solvent is discarded, hazardous waste regulations may also come into play. A complete inventory and chemical review process can identify these issues before the product enters service.

When departments maintain separate inventories using different data sources, inconsistencies can develop. One database may show a product as active while another indicates it is no longer used. A chemical stored in a maintenance room may never make its way into environmental records. These gaps can create reporting errors and complicate inspections.

Small changes can have large compliance impacts

Chemical inventories are not static. New products are introduced, suppliers change formulations, production processes evolve, and maintenance departments purchase materials to address operational needs.

Even seemingly minor changes can affect compliance programs. A reformulated product may contain a reportable constituent that it did not contain previously. A new coating operation may increase air emissions. Additional chemical storage may trigger emergency planning requirements or affect secondary containment needs.

Without a chemical review process involving environmental, safety, operations, and purchasing personnel, facilities may not recognize these implications until well after a change has occurred. This approach helps identify regulatory concerns before products are ordered, stored, or put into use.

Inspections often begin with inventory questions

Environmental inspectors often compare records against actual site conditions. Chemical inventories frequently become a focal point because they intersect with multiple regulatory programs.

Inspectors may compare inventory records with container labels, safety data sheets (SDSs), storage areas, waste accumulation locations, or reported chemical quantities. Discrepancies can raise questions about reporting accuracy and program oversight.

A well-maintained inventory shows that a facility has systems to manage compliance and allows personnel to quickly answer questions about chemical storage and use.

Building a stronger inventory program

The challenge is deciding what information to track and how to keep it current. An effective chemical inventory program does not need to be complicated, but it should be consistent.

At a minimum, facilities should track product names, storage locations, quantities on site, usage rates, SDS information, and key chemical constituents. Different data elements support different programs. Storage quantities may affect EPCRA reporting, chemical constituents may drive TRI evaluations, and usage rates often provide critical data for air emissions calculations. Some organizations also identify whether a product contains TRI chemicals, hazardous air pollutants (HAPs), VOCs, PFAS, or other substances subject to reporting or permitting requirements. Centralizing this information can simplify environmental evaluations throughout the year.

Facilities should establish clear ownership of inventory data, periodically verify inventory accuracy in the field, review new chemicals before purchase, and ensure information is shared across departments. Environmental staff should also periodically compare inventory data against reporting submissions, air permits, waste records, and emergency planning documentation. The goal is not simply to maintain a list of chemicals, but to create a reliable foundation for environmental decision making. A well-managed inventory supports air permitting, chemical reporting, emergency planning, spill prevention, and hazardous waste programs. When inventory data is accurate and readily available, environmental professionals spend less time chasing information and more time managing compliance risks.

Key to remember: Chemical inventory management is more than a recordkeeping exercise. A complete and accurate inventory provides the information needed to support air, waste, emergency planning, spill prevention, and chemical reporting programs, helping facilities identify compliance obligations before problems arise.

EHS Monthly Round Up - July 2026

EHS Monthly Round Up - July 2026

In this July 2026 monthly 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 happened over the past month.

OSHA published its 2026 regulatory agenda on July 3. Of note, the agency projects an April 2027 date for the Emergency Response final rule, and the Heat Illness proposal is slated to be finalized in October 2027. In November 2026, OSHA also expects to publish a final rule addressing the use of subpoenas during investigations.

OSHA reopened the comment period for 14 chemical-specific proposals. This allows the public 30 days to comment on recommendations made by OSHA’s Advisory Committee on Construction Safety and Health.

OSHA updated its Voluntary Protection Programs, which recognize workplaces with strong safety and health programs and low injury rates. The changes align with the seven core elements in the agency’s Recommended Practices for Safety and Health Programs.

The Mine Safety and Health Administration withdrew 4 regulations that it says address outdated effective dates and requirements for various industry equipment and procedures. These relate to conveyor belts, blacksmith shops, diesel emission limits, and permissible flame safety lamps.

Turning to environmental news, EPA released detailed instructions and deadlines for pesticide registrants to begin compliance with the bilingual labeling requirements in the My PeST application. The first compliance deadline was July 31.

EPA aligned regulations under EPCRA Sections 311 and 312 with OSHA’s Hazard Communication amendments for hazardous chemical reporting requirements. Facilities must use OSHA’s hazard classes with their categories for safety data sheet submissions and hazardous chemical inventory reports required under EPCRA Sections 311 and 312.

And finally, EPA published its 2026 regulatory agenda on July 3. Many of the proposed and final rules support the agency’s continued deregulatory efforts and may impact regulatory compliance with air, land, and water rules.

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

EHS Monthly Round Up - February 2026

EHS Monthly Round Up - February 2026

In this Februrary 2026 roundup video, we'll discuss 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 happened over the past month.

Fatal work injuries fell 4 percent in 2024, largely due to a decline in workplace drug- and alcohol-related overdoses. According to the Bureau of Labor Statistics, overdose fatalities fell from 512 in 2023 to 410 in 2024. Across all types of workplace incidents, there were 5,070 fatal work injuries in 2024, compared to 5,283 in 2023. Transportation incidents continue to be the most frequent type of fatal event, accounting for over 38 percent of all occupational fatalities in 2024.

OSHA is fast-tracking a proposal to remove the 2036 obligation to upgrade fall protection systems on fixed ladders that extend over 24 feet. This follows an industry petition from major chemical and petroleum industry groups, which argue the provision is unjustified, costly, and not supported by the rulemaking record. OSHA frames the upcoming proposed action as deregulatory, allowing employers to update fixed ladders at the end of their service lives. We’ll provide updates as more information becomes available.

As OSHA leans into “deregulatory” actions, lawmakers are moving to pressure the agency to issue “regulatory” rulemaking to protect American workers. The latest legislative wave of bills aims to fill regulatory gaps, tackle emerging hazards, expand OSHA authority, and raise penalties. Topics addressed by these bills include musculoskeletal disorders, heat stress, infectious diseases, wildfire smoke, and workplace violence.

In a recently issued letter of interpretation, OSHA states that a burn injury caused by a personal lithium-ion battery fire is work related if it occurs in the workplace during assigned working hours. The letter details an incident where an employee was burned when their rechargeable lithium-ion batteries for e-cigarettes sparked a fire after coming into contact with a key used for work.

A new report from the Department of Labor Office of Inspector General concludes that OSHA struggles to meet its mission, particularly in high-risk industries like healthcare, construction, and manufacturing. Several pages point to OSHA’s difficulties in effectively enforcing annual injury and illness reporting requirements, reaching the nation’s high-risk worksites for inspection, and addressing workplace violence by regulatory or other action.

Turning to environmental news, EPA extended the deadlines for Facility Evaluation Reports and related requirements for coal combustion residuals facilities. In most instances, the deadlines have been moved one or two years out.

And finally, EPA announced a final rule eliminating the 2009 Endangerment Finding and related greenhouse gas emission requirements for on-highway vehicles and vehicle engines. When the final rule takes effect, manufacturers and importers of new motor vehicles and motor vehicle engines will no longer have to measure, report, certify, or comply with federal greenhouse gas emission standards.

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

EHS Monthly Round Up - May 2026

EHS Monthly Round Up - May 2026

In this May 2026 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 happened over the past month.

The first compliance date for the revised HazCom standard took effect May 19. Employers who work with chemical substances that are aerosols, desensitized explosives, or flammable gases should start to see updated safety data sheets and labels. On a related note, OSHA revised its HazCom directive for inspectors. It instructs OSHA officers on how to conduct inspections and issue citations under the standard. However, it also provides chemical manufacturers, importers, distributors, and employers with insight into what officers will be assessing.

OSHA revoked a standard that prohibited open fires and fires in drums or similar containers in marine terminals. The agency stated that since this is no longer typical practice, removing the standard would lessen the compliance burden without compromising worker safety.

OSHA received the backing of an advisory committee as it advances a comprehensive Tree Care Operations proposal. During the Advisory Committee on Construction Safety and Health meeting, the group unanimously voted in favor of moving ahead. This clears the path for OSHA to publish its long-awaited proposal.

Turning to environmental news, EPA extended the submission date for the TSCA Section 8(d) Health and Safety Data Reporting Rule one-time report from May 22, 2026, to May 21, 2027.

EPA published the first round of expiring confidential business information claims for information submitted under TSCA. The list covers claims that expire from June 22 to July 31, 2026. Businesses must submit extension requests to keep the information protected.

EPA postponed the effective compliance date for trichloroethylene users with TSCA Section 6(g) exemptions until pending judicial review is concluded. The agency has yet to establish a new compliance date.

And finally, EPA revised HFC use restrictions for certain subsectors. This applies to entities that are subject to the 2023 Technology Transition Rule requirements. The agency also proposed a rule that would exempt transportation refrigeration units from leak repair requirements regardless of charge size.

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

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