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 PHMSA is also withdrawing the unpublished November 28, 2022, Notice of Enforcement Policy Regarding International Standards on the use of select updated international standards in complying with the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

e-Manifest Third Rule compliance checklist: Countdown to December 1
2025-09-12T05:00:00Z

e-Manifest Third Rule compliance checklist: Countdown to December 1

The date of December 1 often evokes thoughts of colder weather, the start of the Christmas season, and … waste manifests?! That’s certainly the case this year for hazardous waste handlers. On December 1, 2025, the rest of the Third Rule’s compliance requirements for electronic manifests take effect.

The Environmental Protection Agency’s (EPA’s) final Third Rule, established under the Resource Conservation and Recovery Act (RCRA), amends the Hazardous Waste Electronic Manifest System (e-Manifest system) standards. Many of the requirements began in January 2025. The Third Rule’s remaining regulatory changes start on December 1, 2025. Are you prepared to comply?

e-Manifest compliance check

Use this checklist to help you ensure that your business is set to comply with the rest of the Third Rule’s requirements that take effect in December.

Transition to the 4-copy forms

Under the Third Rule, EPA replaced the 5-copy paper manifests and continuation sheets with 4-copy paper manifests (EPA Form 8700-22) and continuation sheets (EPA Form 8700-22A). However, the agency allows hazardous waste handlers to continue using the 5-copy paper forms until further notice. EPA will provide a 90-day notice before it intends to stop accepting the 5-copy forms.

Note: At the time of the publication of this article, EPA has not yet given any authorized printer approval to print the new 4-copy manifest forms. As an authorized printer of the hazardous waste manifest forms, J. J. Keller & Associates, Inc. is working closely with EPA for approval to print the new 4-copy forms.

Users need Certifier permission on the e-Manifest module or Site Manager permission on the RCRA Information (RCRAInfo) Industry Application to submit manifests.

Compliance check:

☑ Begin to use the 4-copy manifests and continuation sheets as soon as they’re made available.

☑ Ensure that at least one user has Certifier or Site Manager permission.

Submit export manifests and related fees to e-Manifest

As of December 1, 2025, domestic hazardous waste exporters must submit all export manifests and continuation sheets (paper and electronic) to the e-Manifest system and pay the associated user fees.

An exporter is considered any entity that originates a manifest to export a hazardous waste shipment. This includes generators; transporters; treatment, storage, and disposal facilities; and recognized traders.

EPA will invoice exporters monthly for the manifest activities conducted during the previous month. The agency applies a fee per manifest, and the amount varies based on the type of submission (scanned image upload, data and image upload, or fully/hybrid electronic manifest).

Only individuals with Site Manager permission on RCRAInfo can pay manifest fees.

Compliance check:

☑ Prepare to use the e-Manifest system for export manifests and pay user fees.

☑ Verify that at least one person has Site Manager permission.

Submit manifest-related reports to e-Manifest

The Third Rule requires hazardous waste handlers to submit all Discrepancy, Exception, and Unmanifested Waste Reports to the e-Manifest system starting on December 1, 2025.

Generators submit Exception Reports, and receiving facilities submit Discrepancy and Unmanifested Waste Reports. No fees apply.

To submit the manifest-related reports to the e-Manifest system, users require Certifier permission for the module.

Compliance check:

☑ Be ready to submit manifest-related reports to the e-Manifest system.

☑ Confirm that at least one user has Certifier permission.

Send manifest copies to exporters

Beginning on December 1, 2025, entities that transport hazardous waste export shipments out of the U.S. (i.e., last transporters) have to send a signed copy of the manifest and continuation sheet to the exporter instead of the generator.

Further, the Third Rule clarifies that starting on December 1, 2025, transporters can use the e-Manifest system to export hazardous waste and send exporters copies of the signed manifest and continuation sheet. Transporters planning to do so need to set up a RCRAInfo account to use the e-Manifest system and assign Certifier permission to the user(s) who will submit the manifests.

Compliance check:

☑ Plan to send signed copies of the manifest and continuation sheet to the exporter.

☑ If applicable, register an account on RCRAInfo, and ensure at least one user has Certifier permission.

Use e-Manifest resources for additional help

EPA has multiple resources to help regulated hazardous waste handlers comply with e-Manifest regulations, including the upcoming Third Rule’s requirements that take effect on December 1, 2025. Consider using the resources the agency provides on “The Hazardous Waste Electronic Manifest (e-Manifest) System” website, such as:

  • Webinars,
  • Demonstration videos,
  • General and user-specific FAQs about the e-Manifest program, and
  • The e-Manifest Helpdesk for industry users.

The compliance checklist and e-Manifest resources can help you ensure that your facility will be ready to comply with the rest of the Third Rule’s requirements by December.

Key to remember: The remaining e-Manifest Third Rule requirements take effect on December 1, 2025. Facilities should confirm that they’re prepared to comply.

Hazardous waste handlers may continue use of 5-copy manifest forms
2025-09-12T05:00:00Z

Hazardous waste handlers may continue use of 5-copy manifest forms

The Environmental Protection Agency (EPA) announced that it will accept 5-copy paper manifest forms from entities regulated by the Resource Conservation and Recovery Act (RCRA) hazardous waste manifest program until further notice.

What changed?

The final Third Rule (effective on January 22, 2025) made multiple changes to the hazardous waste manifest regulations, one of which requires regulated entities to use 4-copy manifests (EPA Form 8700-22) and continuation sheets (EPA Form 8700-22A) instead of the previous 5-copy forms.

Initially, EPA stated that it would no longer accept 5-copy forms starting on December 1, 2025. However, the agency has removed the limit and will accept the 5-copy forms until further notice. Additionally, EPA will give a 90-day notice before the agency plans to stop accepting the 5-copy forms.

As an authorized printer of the hazardous waste manifest forms, J. J. Keller & Associates, Inc. is working closely with EPA for approval to print the new 4-copy forms. At the time of publication of this news article, the federal agency hasn’t yet approved any authorized printer to print the new forms.

Exporter and importer requirements

Hazardous waste exporters and importers that use the 5-copy manifest forms are required to put the consent numbers for their wastes in the Special Handling Instructions and Additional Information Field (Item 14) of the 5-copy manifest. If applicable, exporters must also enter their EPA Identification (ID) Numbers in Item 14. The agency recommends using this format: “Exporter EPA ID #AAANNNNNNNNN."

Please note that we will monitor any additional changes that result from EPA's decision to continue accepting 5-copy paper manifest forms and provide updates accordingly.

Key to remember: EPA will accept 5-copy manifests and continuation sheets beyond the initial deadline of December 1, 2025, until further notice.

Countdown to compliance: EPA’s AIM Act and its impact on refrigerant users
2025-09-11T05:00:00Z

Countdown to compliance: EPA’s AIM Act and its impact on refrigerant users

Starting January 1, 2026, the Environmental Protection Agency (EPA) will enforce sweeping changes under the American Innovation and Manufacturing (AIM) Act, targeting the use and management of hydrofluorocarbons (HFCs)—potent greenhouse gases used in refrigeration, air conditioning, and fire suppression.

These rules apply to all businesses with equipment containing 15 pounds or more of refrigerant with a Global Warming Potential (GWP) over 53, including but not limited to grocery stores, refrigerated transport fleets, repair shops, and small businesses.

Key requirements for end users

1. Leak detection and repair

  • Automatic leak detection systems (ALDs) are mandatory for systems with 1,500 pounds or more of refrigerant.
  • Leaks must be repaired within 30 days or a retirement/retrofit plan must be submitted
  • Leak rate thresholds:
    • Industrial process refrigeration: 30%
    • Commercial refrigeration: 20%
    • Transport & comfort cooling: 10%

2. Refrigerant reclamation

  • Repairs must use reclaimed refrigerants in supermarket systems, refrigerated transport, and commercial ice makers
  • Reclaimed HFCs must contain no more than 15% virgin HFCs and be properly labeled

3. Recordkeeping and reporting

  • Businesses must maintain detailed logs of:
    • Refrigerant purchases and usage
    • Leak events and repairs
    • Equipment servicing and disposal
  • Records must be available for EPA audits at any time.

4. Disposal and recycling

  • HFCs must be recovered from disposable cylinders before disposal
  • Fire suppression systems must be recycled prior to disposal, and technician training is required

Sector-specific impacts

Grocery retailers

  • Must retrofit or replace systems using restricted HFCs like R-404A or R-22
  • Natural refrigerants (CO₂, ammonia) are encouraged but require new equipment and trained technicians
  • Legacy systems may become costly to maintain due to refrigerant scarcity

Refrigerated transport

  • Subject to leak repair thresholds and reclamation rules
  • Must track refrigerant use across fleets and ensure timely repairs

Repair shops

  • Must use reclaimed refrigerants for servicing regulated systems
  • Required to follow EPA labeling and documentation standards

All end users: what you must do now

  • Inventory your equipment: Identify all systems with refrigerants over 15 lbs and GWP greater than 53
  • Install ALDs: For large systems, ensure real-time leak monitoring is in place
  • Train staff: Ensure technicians understand new servicing, reporting, and disposal rules
  • Upgrade Recordkeeping: Use digital tools to automate tracking and reporting

Looking ahead: state-level rules may be stricter

States like California, Washington, and New York are implementing stricter refrigerant rules that may exceed federal AIM Act standards. Businesses operating across state lines must monitor local regulations and prepare for additional reporting and inspections.

Key to remember: If your business uses refrigerants, the AIM Act likely applies to you. Start preparing now to avoid penalties and ensure compliance by 2026.

EPA's Spring 2025 regulatory agenda focuses on PFAS, fossil fuels, and rule reconsiderations
2025-09-09T05:00:00Z

EPA's Spring 2025 regulatory agenda focuses on PFAS, fossil fuels, and rule reconsiderations

The Environmental Protection Agency (EPA) published the Spring 2025 Semiannual Agenda of Regulatory and Deregulatory Actions on August 30, 2025. The agenda outlines the agency’s upcoming regulatory actions and their status in the rulemaking process.

EPA has major updates on the docket, such as:

  • Repealing all greenhouse gas (GHG) standards for fossil fuel-fired power plants and the 2024 amendments to the Mercury Air Toxics Standard for power plants (final rules expected December 2025);
  • Establishing risk management rules for multiple chemical substances, such as 1-bromopropane and n-methylpyrrolidone (final rules expected April 2026);
  • Adding hazardous waste solar panels to the federal universal waste program and setting universal waste standards specific to lithium batteries (proposed rule expected February 2026);
  • Setting the Renewable Fuel Standards for 2026 and 2027 and implementing regulatory program changes (final rule expected October 2025); and
  • Reconsidering current rules, like:
    • The GHG Reporting Program (final rule expected November 2025),
    • The National Emission Standards for Hazardous Air Pollutants (NESHAP) for iron and steel and the NESHAP for oil and natural gas (proposed rules expected November 2025 and December 2025, respectively), and
    • The 2024 amendments to the procedures for conducting Toxic Substances Control Act chemical risk evaluations (final rule expected April 2026).

Additionally, the agency intends to address per- and polyfluoroalkyl substances (PFAS) across multiple media. For example, EPA plans to:

  • Rescind the National Primary Drinking Water Regulations for PFHxS, PFNA, GenX, and mixtures of these three as well as for PFBS (proposed rule expected September 2025);
  • Add certain PFAS to the Toxics Release Inventory (final rule expected February 2026); and
  • Address PFAS discharges from PFAS manufacturers (proposed rule expected January 2026).

This article highlights some of the major rules we’re monitoring closely. You can review the entire agenda to learn about all the rulemakings on EPA’s docket. Please note that the agenda dates are tentative, indicating when the agency seeks to publish the rulemakings in the Federal Register.

Final Rule Stage
Projected publication dateTitle
December 2025Phasedown of Hydrofluorocarbons: Reconsideration of Certain Regulatory Requirements Under the Technology Transitions Provisions of the American Innovation and Manufacturing Act of 2020
January 2026Accidental Release Prevention Requirements: Risk Management Programs Under the Clean Air Act; Common Sense Approach to Chemical Accident Prevention
February 2026Addition of Certain Per- and Polyfluoroalkyl Substances (PFAS) to the Toxics Release Inventory (TRI)
February 2026Initial Air Quality Designations for the 2024 Revised Primary Annual Fine Particle (PM2.5) National Ambient Air Quality Standards (NAAQS)
April 2026Listing of Specific PFAS as Hazardous Constituents
Proposed Rule Stage
Projected publication date of notice of proposed rulemaking
Title
October 2025Effluent Limitations Guidelines and Standards for the Oil and Gas Extraction Category (40 CFR 435 Subpart E)
October 2025New Source Performance Standards for the Synthetic Organic Chemical Manufacturing Industry and National Emission Standards for Hazardous Air Pollutants for the Synthetic Organic Chemical Manufacturing Industry
November 2025Additional Reconsideration of Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review
November 2025PFAS Requirements in NPDES Permit Applications
November 2025Steam Electric Effluent Limitations Guideline Reconsideration Rule
December 2025Updates to the RCRA Hazardous Waste Regulations and Related Technical Corrections — Permitting Updates Rule 
January 2026Paper Manifest Sunset Rule; Modification of the Hazardous Waste Manifest System 
January 2026Revision to “Begin Actual Construction” in the New Source Review Preconstruction Permitting Program
April 2026Reconsideration of National Emission Standards for Hazardous Air Pollutants: Gasoline Distribution Technology Reviews and New Source Performance Standards Review for Bulk Gasoline Terminals
May 2026Formaldehyde; Regulation Under the Toxic Substances Control Act (TSCA)
Pre-Rule Stage
Projected publication date or other actionTitle
September 2025 (advanced notice of proposed rulemaking)Visibility Protection: Regional Haze State Plan Requirements Rule Revision
December 2025 (end review)National Emission Standards for Hazardous Air Pollutants for Brick and Structural Clay Products Manufacturing; and Clay Ceramics Manufacturing
Key to remember: EPA’s planned rulemakings may impact regulatory compliance with air, land, and water rules.
EHS Monthly Round Up - August 2025

EHS Monthly Round Up - August 2025

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

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

OSHA extended the comment period for multiple proposed rules it published on July 1. Stakeholders now have an extra 60 days, until November 1, to comment. Impacted rules include those for respiratory protection, construction illumination, COVID-19, and the General Duty Clause.

OSHA is expanding its Voluntary Protection Programs to help employers develop strong safety programs and lower injury rates. To participate, employers must submit an application to OSHA and undergo an onsite evaluation by a team of safety and health professionals.

Following a series of recent trench collapses, OSHA urges employers to take steps to protect workers. Trench collapses can be prevented by sloping or benching trench walls at an angle, shoring trench walls with supports, and shielding walls with trench boxes. More information can be found on OSHA’s website.

The Mine Safety and Health Administration launched a webpage for its new Compliance Assistance in Safety and Health, or CASH, program. The agency anticipates a surge in domestic mining productivity and seeks to proactively provide miners and mine operators with compliance assistance materials.

Turning to environmental news, EPA proposes challenges to California’s Clean Truck Check program. The program aims to reduce emissions of nitrogen oxides and particulate matter for heavy-duty vehicles. EPA supports the regulation as it applies to California-registered vehicles but disapproves the regulation as it applies to out of state and out of country vehicles. Stakeholders have until September 25 to comment on the proposal.

On August 14, EPA released the July 2025 nonconfidential TSCA Inventory of chemical substances manufactured, processed, or imported in the U.S. The Inventory contains over 86 thousand chemicals, nearly half of which are in active use. The next inventory update is planned for late 2026.

And finally, EPA proposes to rescind the 2009 Endangerment Finding and repeal greenhouse gas emissions for new motor vehicles and vehicle engines. The agency will accept comments on the proposal through September 15.

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

See More

Most Recent Highlights In Transportation

Update: EPA withdraws direct rule, keeps proposed rule for alternative CCR reporting option
2025-09-05T05:00:00Z

Update: EPA withdraws direct rule, keeps proposed rule for alternative CCR reporting option

On September 4, 2025, the Environmental Protection Agency (EPA) withdrew a direct final rule it issued on July 22, 2025, that offered active and inactive coal combustion residuals (CCR) facilities an alternative reporting option and delayed corresponding compliance obligations for CCR management units (CCRMUs). However, the parallel proposed rule that was published with the direct final rule remains in place, and EPA has extended the comment period through September 15, 2025.

Who does this affect?

The direct and proposed rules impact (a) active CCR facilities and (b) inactive CCR facilities with inactive surface impoundments (called legacy CCR surface impoundments) that are regulated by the 2024 Legacy Rule.

What does this mean?

Because the direct rule was withdrawn, the alternative reporting option for the Facility Evaluation Report (FER) Part 1 doesn’t apply, and the compliance deadlines for the related CCRMU requirements revert to the previous timelines.

The parallel proposed rule remains active and contains the same changes as the withdrawn direct final rule, including:

  • Adding an alternative option for active CCR facilities and legacy CCR surface impoundments to submit FER Parts 1 and 2 together by February 8, 2027; and
  • Extending the related compliance deadlines for facilities with CCRMUs.

Further, the proposed rule seeks public input on potentially delaying both FER reporting deadlines and adjusting the CCRMU compliance timelines accordingly. The proposed additional extension would give CCR facilities the option to:

  • Submit FER Part 1 by February 8, 2027, and FER Part 2 by February 8, 2028; or
  • Submit FER Parts 1 and 2 together by February 8, 2028.

You can submit comments to Docket ID No. EPA-HQ-OLEM-2020-0107.

Please see the original Industry News article ("EPA offers CCR facilities delayed reporting option and extends compliance deadlines") for more information about the withdrawn direct rule and the active proposed rule.

Key to remember: EPA has withdrawn a direct final rule that offered active and inactive coal combustion facilities an alternative reporting option, but the agency has kept the corresponding proposed rule in place.

OSHA renews alliance to improve worker safety in waste and recycling industry
2025-09-03T05:00:00Z

OSHA renews alliance to improve worker safety in waste and recycling industry

In a renewed alliance, OSHA, the National Waste & Recycling Association (NWRA), and the Solid Waste Association of North America (SWANA) will continue to work together to improve the safety and health of workers in the solid waste and recycling industry.

The partnership will focus on safety issues such as:

  • Transportation hazards;
  • Slips, trips, and falls;
  • Needlestick and musculoskeletal injuries; and
  • Health issues associated with lithium battery hazards in waste/recycling collection and processing.

OSHA, NWRA, and SWANA will develop resources to help employers prevent and mitigate hazards, including:

  • Educational articles,
  • Fact sheets, and
  • Toolkits.

The group will share these resources and additional information at conferences, forums, and meetings, with much of their outreach aimed at reaching small- and medium-sized employers who may have limited access to safety information.

2025-08-29T05:00:00Z

New Mexico bans PFAS from oil and gas well completions and recompletions

Effective date: July 29, 2025

This applies to: Oil and gas operations

Description of change: The New Mexico Oil Conservation Commission adopted amendments to ban per- and polyfluoroalkyl substances (PFAS) from being used in completions (bringing into production) or recompletions (restarting production) of oil wells. The amendments to 19.15 N.M.A.C.:

  • Require operators to provide certification that no PFAS chemicals were used;
  • Require applicants for a permit to drill, deepen, or plug back a well to certify that they won’t introduce PFAS-containing additives;
  • Adds completion operations to the factors that trigger notification and diligence action requirements when potential loss of containment or damage occurs; and
  • Adds FracFocus disclosure requirements.
2025-08-29T05:00:00Z

Colorado provides alternative window, door, skylight efficiency standards

Effective date: January 1, 2026

This applies to: Residential windows, doors, and skylights sold or leased for residential use in the state

Description of change: As of January 1, 2026, all residential windows, doors, and skylights sold or leased for residential use in Colorado must meet specific energy efficiency standards established by House Bill 23-1161. The Colorado Energy Office established an alternative energy standard for compliance. Manufacturers may choose between the standard at C.R.S. 6-7.5-105(5)(j)(l) and the alternative standard at 5 CCR 1004-2(1.1).

2025-08-29T05:00:00Z

Washington updates protocol for Cap-and-Invest Program

Effective date: August 21, 2025

This applies to: Businesses subject to the Climate Commitment Act Program rule

Description of change: The Department of Ecology updated the offset protocol for ozone-depleting substances (ODS) to expand the scope of offset projects available to Cap-and-Invest Program participants. The amendments to chapter 173-446 WAC:

  • Restrict project invalidation liability for ODS projects,
  • Adopt a new ODS protocol based on one used by the California Air Resources Board, and
  • Require all ODS offset projects that begin after the effective date of this rule to use the new protocol.

View related state info: Clean air operating permits — Washington

See More

Most Recent Highlights In Safety & Health

2025-08-29T05:00:00Z

Colorado revises water well construction rules

Effective date: January 1, 2026

This applies to: Entities subject to the Well Construction Rules

Description of change: The Board of Examiners of Water Construction and Pump Installation Contractors adopted amendments to:

  • Establish online, open-book assessments for well owners constructing wells or installing pumping equipment;
  • Change well construction requirements for Confined (Type 1) Aquifers by:
    • Expanding minimum annular space for grout,
    • Specifying sealing requirements,
    • Allowing solid casing for all confined aquifer wells, and
    • Allowing solid granular bentonite for minimum grouting requirements.
  • Change monitoring and observation requirements by:
    • Establishing minimum grouting interval and grouting annular space requirements,
    • Restricting filter packs to the monitored interval, and
    • Improving abandonment requirements.
2025-08-29T05:00:00Z

California strengthens Low Carbon Fuel Standard

Effective date: July 1, 2025

This applies to: Any entity that sells or supplies transportation fuel in the state

Description of change: The California Air Resources Board (or CARB) amended the Low Carbon Fuel Standard (LCFS) to set more stringent LCFS carbon intensity (CI) benchmarks. The amendments require:

  • A 30 percent reduction in fuel CI by 2030, and
  • A 90 percent reduction in fuel CI by 2045.

The amendments also:

  • Adopt a near-term step down of CI benchmarks and automatic increases of CI benchmark stringency when triggered;
  • Streamline application and reporting requirements, quantification methods, and analysis tools; and
  • Updates third-party verification and validation requirements.

View related state info: Greenhouse Gas Emissions Regulation State Comparison

2025-08-29T05:00:00Z

Rhode Island adds monthly recordkeeping flexibility

Effective date: June 6, 2025

This applies to: Sources required to record monthly data for nitrogen oxide emissions and/or distributed/emergency generators with a general permit

Description of change: The Office of Air Resources removed monthly recordkeeping limits for:

  • Stationary sources that emit nitrogen oxides (NOx), and
  • Stationary sources with general permits for emergency generators and distributed generators.

The office amended Part 27 to remove the requirement to record within the first 15 days of the month:

  • Fuel usage and the quantity of NOx emitted, and/or
  • The hours of operation for each engine and/or combustion unit.

The office also amended Part 43 to remove the requirement to record within the first five days of the month:

  • Fuel usage for each distributed generator, and/or
  • Hours of operation for each emergency generator.

Sources may record the data at any time within the month.

View related state info: Clean air operating permits — Rhode Island

ABCs of UST operator training
2025-08-28T05:00:00Z

ABCs of UST operator training

“Operator error” isn’t something anyone likes to see, especially when it applies to leaks from underground tanks of petroleum or hazardous materials. That’s why it’s essential to train individuals to manage underground storage tanks (USTs) correctly. Training obligations vary for each type of UST operator. Federal regulations establish three categories:

  • Class A operators,
  • Class B operators, and
  • Class C operators.

Properly trained operators are vital to managing USTs safely and in compliance. Use this guide to understand the different training requirements for Class A, B, and C operators.

An overview of roles

The Environmental Protection Agency (EPA) requires all owners and operators of UST systems to designate:

  • One Class A operator and one Class B operator for each UST or groups of USTs, and
  • Each qualifying person at the facility as a Class C operator.

Class A operators are responsible for operating and maintaining USTs in line with the regulations. A Class A operator generally manages the resources and personnel involved to ensure UST operations comply.

A successfully trained Class A operator:

  • Makes informed decisions about compliance; and
  • Determines whether the facility complies with operation, maintenance, and recordkeeping requirements.

Class B operators handle the day-to-day responsibilities for managing USTs (like conducting in-field operations).

A Class B operator with sufficient training implements applicable regulatory requirements in the field on typical UST system components or site-specific equipment.

Class C operators provide immediate responses to UST-related problems.

An adequately trained Class C operator takes the necessary response actions to emergencies or alarms caused by UST spills and releases.

Basic training requirements

EPA outlines the minimum training requirements for each operator type at 40 CFR Part 280 Subpart J. All classes of operators must be trained or pass a comparable examination. Class C operators have the additional option to receive training from a Class A or B operator at the facility.

A facility can designate an individual for multiple operator classes. Any person with multiple designations must complete the required training or comparable examination for all applicable classes.

Class A and Class B operators must be trained within 30 days of beginning UST duties. Class C operators have to be trained before starting their UST responsibilities.

Class A operators should understand the purpose, methods, and functions of:

  • Spill and overfill prevention;
  • Release detection;
  • Corrosion protection;
  • Emergency response;
  • Product and equipment compatibility and demonstration;
  • Financial responsibility;
  • Notification and storage tank registration;
  • Temporary and permanent closure;
  • Related reporting, recordkeeping, testing, and inspections;
  • Environmental and regulatory consequences of releases; and
  • Training requirements for Class B and Class C operators.

Class B operators may be trained in either:

  • General requirements for all compliance rules and the equipment commonly used at UST facilities, or
  • Site-specific requirements that only cover the regulations and equipment applicable to the facility.

Additionally, Class B operators need to know the purpose, methods, and functions of:

  • Operation and maintenance;
  • Spill and overfill prevention;
  • Release detection and related reporting;
  • Corrosion protection;
  • Emergency response;
  • Product and equipment compatibility and demonstration;
  • Reporting, recordkeeping, testing, and inspections;
  • Environmental and regulatory consequences of releases; and
  • Training requirements for Class C operators.

Class C operators must know how to respond with the correct actions to emergencies or alarms that are caused by spills or releases from UST operations, including notifying the authorities.

Common training questions

Consider these FAQs to help ensure your UST operator training programs comply.

How are operators evaluated?

Facilities must evaluate each operator via testing, a practical demonstration, or another approved approach.

When is retraining required?

If a UST system is found to be noncompliant, Class A and Class B operators at the facility must complete a training program or comparable examination that at least covers the areas out of compliance (unless exempt per 280.244).

Retraining should be completed within 30 days of the noncompliance determination. The training program or examination has to be developed or administered by a third party (i.e., an independent organization, the implementing agency, or a recognized authority).

How is training tracked?

Facilities are required to keep paper or electronic records that verify training and retraining for as long as the operators are designated. The records should contain at a minimum the information at 280.245(b).

What about state requirements?

It’s essential to check state UST regulations where your facilities operate. EPA has approved most states to implement the UST program. State requirements are at least as stringent as federal standards, and many state programs impose stricter rules.

Usually, operator training is obtained from third-party organizations that must be registered and approved by state environmental agencies to ensure the programs comply with federal and state requirements.

Key to remember: Training requirements for underground storage tank operators are based on their designated class: A, B, or C.

Avoiding compliance pitfalls: Understanding the overlap between HAPs and VOCs
2025-08-25T05:00:00Z

Avoiding compliance pitfalls: Understanding the overlap between HAPs and VOCs

Understanding how hazardous air pollutants (HAPs) and volatile organic compounds (VOCs) are counted is key to accurate reporting and staying in compliance. These pollutants often overlap, but how they're treated depends on the situation — especially when comparing emission inventories to permitting rules. Misunderstanding the differences can lead to underreporting, permit mistakes, and other compliance problems. This article will also discuss how state rules can make things more complex.

Emission inventories: often counted together

Emission inventories help regulatory agencies track actual emissions from facilities over time. These records support air quality models, guide policy, and help protect public health.

In many cases, HAPs that are also VOCs (like toluene or xylene) are included in the total VOC count. For example, the Environmental Protection Agency (EPA) includes HAP-VOCs in its National Emissions Inventory, which supports regional air quality models, like the Community Multiscale Air Quality (CMAQ) system.

Frequently Asked Question: What's the National Emissions Inventory?

As an example, the Texas Commission on Environmental Quality recommends using conservative “first-cut” estimates for both VOCs and HAPs. This makes early reporting easier and helps avoid underestimating emissions.

Potential to emit (PTE): counted separately

PTE calculations are used to determine a facility’s regulatory status, such as whether it qualifies as a major source under the New Source Review (NSR) or Title V programs or is subject to Maximum Achievable Control Technology (MACT) standards.

In this context, HAPs and VOCs are counted separately because they're subject to different thresholds, including:

  • 10 tons per year (TPY) for a single HAP or 25 TPY for total HAPs; and
  • Typically 100 TPY for major source classification under NSR, though this can vary by attainment status.

This separation is critical. A facility might exceed the HAP threshold and trigger MACT requirements, even if its VOC emissions are below NSR thresholds — or vice versa. As an example, if a paint booth has the potential to emit 500 pounds of toluene, this is counted as 500 pounds of HAP and 500 pounds of VOC. Even though that seems like double-counting for the same emission, it's important to include both totals separately.

State-by-state variability

While federal rules provide a baseline, states often have their own interpretations and requirements:

  • Ohio offers detailed guidance on calculating VOC and HAP emissions separately for permitting purposes. Facilities must demonstrate compliance with both sets of thresholds.
  • Texas uses a tiered approach. Facilities begin with conservative estimates and refine them only if emissions approach regulatory thresholds.
  • California maintains stricter standards and often requires separate reporting for toxic air contaminants (TACs), which include many HAPs. The state’s Air Toxics Hot Spots Program adds another layer of complexity.

Why the distinction matters

Failing to understand how HAPs and VOCs are counted can lead to serious compliance issues:

  • Permitting errors: Misclassification can result in incorrect permit applications or missed regulatory obligations.
  • Underreporting risks: Facilities may inadvertently underreport emissions if they assume HAPs are always included in VOC totals.
  • Modeling impacts: While combined inventories help with regional modeling, they may obscure the risks posed by individual pollutants.

Recommendations for facilities

To stay compliant and avoid costly mistakes, implement the following:

  • Check state guidance: Requirements vary widely. Always consult your state environmental agency.
  • Use Safety Data Sheet data: Identify both VOC and HAP content in raw materials.
  • Maintain separate records: Keep VOC and HAP data distinct, especially for PTE calculations.
  • Consult experts: When in doubt, seek help from J. J. Keller & Associates, Inc. subject matter experts using the Expert Help feature.

Key to Remember: The way HAPs and VOCs are counted depends heavily on context. Understanding these distinctions — and how they vary by state — is key to maintaining compliance and protecting air quality.

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Most Recent Highlights In Human Resources

Clock ticking for bilingual pesticide labels; EPA reveals tracking method and Q&As
2025-08-21T05:00:00Z

Clock ticking for bilingual pesticide labels; EPA reveals tracking method and Q&As

A 2022 law requires that some sections of end-use pesticide product labeling be translated into Spanish. So, now the Environmental Protection Agency (EPA) has issued a notice requesting comments on how it wants to track the adoption of bilingual labeling. The agency also updated its Bilingual Labeling Questions & Answers webpage.

Spanish translations prompted by law

The Pesticide Registration Improvement Act (PRIA) has been enacted and reauthorized five times. The latest version (PRIA 5) was signed on December 29, 2022. It amended the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) to require Spanish language translation for sections of the end-use pesticide product labels. However, those translations are only required where translation is available in EPA's Spanish Translation Guide for Pesticide Labeling.

Those sections deal with the health and safety of the product. Specifically, the guide has Spanish translations of the:

  • “Keep out of reach of children” statement,
  • Restricted use pesticide (RUP) statement for restricted use products,
  • Misuse statements,
  • Signal word,
  • First aid section,
  • Precautionary statements,
  • Personal protective equipment section,
  • Engineering controls,
  • Environmental hazards,
  • Physical or chemical hazards, and
  • Storage and disposal statements.

Methods of communicating translations

When a registered pesticide product is released for shipment, PRIA 5 requires translations or a link to translations on the product container. Any link would be via scannable technology or other accessible methods. Antimicrobial pesticide products and non-agricultural/non-RUP products have yet another option. They may provide a link to the Spanish Safety Data Sheets instead of a link to label translations.

Deadlines for translations

PRIA 5 establishes a rolling schedule for the implementation of bilingual labeling. The schedule runs from December 2025 to 2030, with the translations for the most hazardous and toxic pesticide products required first. In fact, EPA is starting with RUPs and agricultural pesticides classified as acute toxicity category I. All end-use pesticide labels must have translations by 2030. 

The dates when bilingual labeling is due are based on pesticide product type:

Pesticide product type:Bilingual labeling due:
RUPsDecember 29, 2025
Agricultural products (non-RUPs):
Acute toxicity category IDecember 29, 2025
Acute toxicity category IIDecember 29, 2027
Antimicrobial and non-agricultural products:
Acute toxicity category IDecember 29, 2026
Acute toxicity category IIDecember 29, 2028
All other pesticide productsDecember 29, 2030

EPA tracking required

PRIA 5 also requires EPA to develop, implement, and make publicly available a plan for keeping track of the adoption of bilingual labeling. The agency previously proposed and received comments on using the annual paper maintenance fee filing form to track adoption. It would have used a checkbox to indicate whether products included bilingual labeling.

However, EPA has scrapped that approach. It’s now proposing to track adoption through its electronic MyPeST app. In this case, registrants would electronically check a box next to each pesticide product indicating whether it includes the required bilingual labeling. MyPeST would display product information — such as product type and signal word — to help registrants determine their products’ compliance dates.

The agency also wants to add a checkbox to MyPeST to indicate that a pesticide product will not be released for shipment. This helps distinguish between noncompliance and nonapplicable circumstances.

For tracking purposes, registrants would not need to submit the labels to EPA.

EPA seeks comments

Comments on the proposed tracking method must be received on or before September 19, 2025. Send comments to docket ID EPA-HQ-OPP-2025-0049 at www.regulations.gov. Any comments are welcome, but EPA is particularly looking for examples of how it could reduce this tracking paperwork burden for businesses employing fewer than 25 workers.

The proposed method is anticipated to take 24 hours and cost just over $3,000 per covered entity per year. Entities potentially affected by the notice and comment request include:

  • Pesticide importers,
  • Pesticide manufacturers, and
  • Government establishments responsible for agricultural pest/weed regulation.

Q&As available

EPA says it has also updated its Bilingual Labeling Questions & Answers webpage. Additional questions and answers touch on topics relating to, but not limited to:

  • Enforcement,
  • Supplemental distributor labels,
  • QR codes and websites already on the label, and
  • How to handle subsequent label changes. 

This living document now has over 50 Q&As. It will be updated as PRIA 5 requirements and deadlines are met and new information is available.

Key to remember

EPA issued a notice requesting comments by September 19 on how it wants to track the adoption of bilingual labeling. Spanish language translation for sections of the end-use pesticide product labels has a rolling schedule from 2025 to 2030. The agency also updated its Bilingual Labeling Questions & Answers webpage.

EPA releases July 2025 TSCA Inventory
2025-08-15T05:00:00Z

EPA releases July 2025 TSCA Inventory

On August 14, 2025, the Environmental Protection Agency (EPA) released the biannual update to the nonconfidential Toxic Substances Control Act (TSCA) Chemical Substance Inventory (TSCA Inventory). The inventory includes all TSCA-regulated chemical substances manufactured, processed, or imported in the U.S.

The July 2025 TSCA Inventory contains 86,862 chemicals, adding 15 chemical substances since the last update. Nearly half of the substances (42,578) are active (i.e., in use). EPA also updated:

  • Commercial activity data,
  • Unique identifier data, and
  • Regulatory flags (which identify substances with manufacturing or use restrictions as well as substances with full or partial reporting exemptions).

Further, the agency updated the TSCA Master Inventory File. It includes chemical identity information claimed as confidential that’s excluded from the nonconfidential TSCA Inventory. The TSCA Master Inventory File is the only list with comprehensive, authoritative information about which chemical substances are on the inventory.

The agency plans to make the next inventory update in Winter 2026.

How do I access the inventory?

View the TSCA Inventory by:

  • Downloading the Microsoft Access or CSV text version of the data from EPA’s website, or
  • Using EPA’s Substance Registry Services (SRS).

How does this impact my business?

The TSCA Inventory helps facilities determine compliance requirements for chemicals they (a) manufacture or use or (b) plan to manufacture or use. Chemicals that are on the TSCA Inventory are likely subject to rules, like manufacturing limits and reporting requirements. Chemicals that aren’t on the list must meet notification and review requirements before they can be used.

Key to remember: EPA released the July 2025 nonconfidential TSCA Inventory of chemical substances manufactured, processed, or imported in the U.S.

Smart pretreatment: How digital tools are transforming industrial wastewater management
2025-08-12T05:00:00Z

Smart pretreatment: How digital tools are transforming industrial wastewater management

Industrial wastewater pretreatment systems are evolving quickly. With tighter regulations, aging infrastructure, and rising costs, many facilities are turning to digital tools to modernize their operations. From real-time monitoring to predictive analytics, these technologies help permitted systems stay compliant, reduce risks, and improve performance.

Real-time monitoring improves oversight and response

One of the most important advancements is the use of real-time sensors and Supervisory Control and Data Acquisition (SCADA) systems. These tools allow operators to monitor key factors like pH, flow rate, temperature, and contaminant levels around the clock. If something goes out of range, alerts are sent immediately – helping prevent violations and environmental damage.

Automated sampling and reporting also make it easier to meet regulatory requirements. By reducing manual work and improving accuracy, facilities can respond faster to changes in discharge conditions. This is especially helpful in industries where wastewater characteristics vary, such as food processing or chemical manufacturing.

Predictive analytics and AI support proactive management

Beyond monitoring, predictive analytics and artificial intelligence (AI) help facilities anticipate problems before they happen. By analyzing past data, these systems can predict equipment failures, detect changes in influent quality, and recommend better chemical dosing strategies.

Such a proactive approach reduces downtime, lowers maintenance costs, and improves treatment results. It also helps with long-term planning by identifying trends that may point to needed upgrades or process changes.

Digital twins enable safer, smarter optimization

Some facilities are using digital twins – virtual models of their pretreatment systems. These models simulate real-world operations, allowing engineers to test changes in flow, chemical use, or equipment without affecting actual processes.

Digital twins are also useful for training. New staff can explore how the system works and practice emergency responses in a safe, controlled environment.

Cybersecurity and data protection are growing priorities

As more systems become connected, cybersecurity is a growing concern. Facilities must protect their digital systems from unauthorized access and data breaches. This includes using secure networks, encrypted communication, and regular system checks to ensure data is safe and reliable.

Looking ahead: integration and interoperability

The future of smart pretreatment lies in system integration. Facilities are looking for platforms that combine data from sensors, lab tests, maintenance logs, and compliance reports. When digital tools work together, operators get a clearer view of system performance and can make better decisions.

Key to Remember: Digital tools are no longer optional—they’re essential for modern industrial wastewater pretreatment. By adopting smart technologies, facilities can improve compliance, reduce costs, and support environmental goals.

Use chemical risk evaluations to plan ahead
2025-08-12T05:00:00Z

Use chemical risk evaluations to plan ahead

Wouldn’t it be helpful to know ahead of time if a chemical that your facility uses may soon face additional or stricter regulations? Such an alert system exists! It’s in the form of risk evaluations conducted by the Environmental Protection Agency (EPA).

The Toxic Substances Control Act (TSCA) requires EPA to evaluate existing chemicals in the U.S. marketplace for safety. If the agency determines that a chemical substance poses an unreasonable risk to human or environmental health, it immediately begins the risk management process. Through the process, EPA develops compliance rules to control the risk.

Consider EPA’s final risk evaluation for 1,1-dichloroethane published in June 2025. In it, the agency determined that three uses present an unreasonable risk of injury to workers. EPA will now develop and finalize regulations to address the risk.

If EPA issues a final risk evaluation on a chemical substance that your facility manufactures (including imports), processes, distributes, uses, and/or disposes of, take note! It answers multiple questions that can help your facility prepare for future compliance obligations.

Will my facility have to comply?

EPA’s risk evaluation determines whether an existing chemical substance presents an unreasonable risk to health or the environment under specific conditions of use (COUs). Risk management regulations only apply to the COUs that present an unreasonable risk. If your facility engages in any covered COU, it will have to comply with the applicable future restrictions.

Let’s revisit the 1,1-dichloroethane risk evaluation. One of the three COUs that endanger the health of workers through inhalation exposure is the processing of the chemical substance for recycling. If a facility doesn’t process 1,1-dichloroethane for recycling, it won’t have to comply with future regulations for that COU.

Who’s affected?

The final risk evaluation defines the categories of human and environmental populations covered by the assessment (such as consumers, the general population, workers, and aquatic species), and it identifies the COUs that apply to them.

Knowing the types of populations that a covered COU affects can help facilities narrow down the kinds of compliance requirements that may apply. For instance, a final risk management rule may require facilities to:

What’s the regulatory timeline?

TSCA grants EPA one year from the publication date of the final risk evaluation to propose a risk management rule and another year after that to finalize it. So, potentially covered facilities can expect regulations within two years of the final risk evaluation.

For example, EPA published the final risk evaluation for 1,1-dichloroethane in June 2025, so the agency should finalize a rule by June 2027.

Compliance obligations for a final rule likely won’t begin immediately; EPA usually gives facilities time to make any needed changes to things like operations, equipment, etc.

How can my facility prepare?

Keep these tips in mind:

  • Search for safer alternative chemical substances to use. In addition to eliminating the potential for new or additional compliance requirements, using a safer alternative can offer your business a competitive advantage. EPA’s Safer Chemical Ingredients List may be a good place to start.
  • Look for ways to reduce employee exposure to the chemical substance. Evaluate your facility’s existing operations for ways to lower worker exposure. Consider things like changing work processes or upgrading to equipment with more protective features.
  • Participate in the rulemaking. EPA will open its proposed risk management rule for public comments. You can provide feedback on the compliance requirements the agency plans to impose on regulated facilities. EPA will consider the public comments it receives before finalizing a rule.

Key to remember: EPA’s final chemical risk evaluations give facilities a heads-up that compliance changes are likely within the next couple of years.

EHS Monthly Round Up - July 2025

EHS Monthly Round Up - July 2025

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

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

In response to Executive Orders calling for deregulation efforts, on July 1 OSHA issued one final rule and 25 proposed rules. The proposed rules cover a variety of topics, including respiratory protection, construction illumination, safety color codes for signs, and the General Duty Clause. Stakeholders have until September 2 to comment on them. The final rule took effect July 1 and makes changes to the rules of procedure for promulgating, modifying, and revoking standards applicable to construction work.

OSHA updated its penalty guidance for small employers, impacting businesses with 25 or fewer employees. This includes reduced penalties of up to 70 percent in certain circumstances. These changes took effect July 14.

Effective July 1, California OSHA extended its safety and health laws to protect domestic workers, such as house cleaners, caregivers, and gardeners. The laws apply to businesses that employ both temporary and permanent domestic service workers.

OSHA’s Safe + Sound Week is scheduled for August 11-17 and focuses on emergency preparedness and response. Businesses of all sizes are encouraged to participate by conducting safety stand-downs, evacuation drills, or other activities that help highlight the importance of safety and health programs. More information and resources can be found on OSHA’s website.

And finally, turning to environmental news, EPA issued a final rule that offers coal combustion facilities an alternative option to comply with the Facility Evaluation Report. It also adjusts the compliance timelines for regulations related to coal combustion residuals management units. In addition, EPA issued a proposed rule requesting public feedback on further delaying the Facility Evaluation Report.

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

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