So some people say. Others say different. It would be fairly easy to fill up a page discussing the relative merits of big vs. small and short vs. tall. But that’s too easy, although I must admit almost irresistible. After all, my 5 ‘2” wife has a t-shirt that says something like “people grow until they are just right and some get there sooner than others”, which I hope isn’t a commentary on her 6’3” husband. Or, in view of the recent history of marine incidents a slightly risqué ‘size matters or not’ saying could be made DG relevant by morphing it to “It’s not the size of the ship, it’s the stowage of the undeclared fireworks”. Not today though. We’re sticking with Hazardous Materials in this size matter column, no matter the temptation to go astray. And surprisingly, there’s quite a bit to discuss that isn’t related to Limited or Excepted Quantities.
This topic comes about because the USA is struggling to adjust as their OSHA (Occupational Safety) regulations transition to GHS. MSDS’s become SDS’s, content becomes mandatory and 16-section format becomes mandatory. And one big problem is that SDS authors mistakenly believe that Section 14 can be accurately completed based solely upon the intrinsic properties of the Material described by the Data Sheet. Here should be enough examples to convince you of this as a fallacy.
One of the greatest attributes of objective classification criteria (yes, there are still some subjective criteria in post-GHS transport regulations) is that tests can tell you whether a material is regulated or not. Self-heating tests do offer both these possible outcomes, DG or not DG. But self-heating tests also offer those outcomes conditional upon the size of the shipment. And these are two, not just one, size thresholds. So, we get a lot more than two possible outcomes. We get ‘regulated in all sizes as PG II’, ‘regulated in all sizes as PG III’, ‘regulated above 450 L volume but non-regulated below’, ‘ regulated above 3000 L (3 m3), but not below’ and ‘non-self-heating in all volumes’. Sure, you could agree that use of the volumetric cutoffs is voluntary, that a shipper could choose to regulate in smaller volumes when they don’t have to, but, really who is going to pay for DG fees, DG packaging, DG training and take on all the additional DG requirements for a 5 kg shipment if they aren’t required to do so until the size of the shipment reaches 3000 L? So, realistically and practically, their Section 14 entries may need to vary with the size of the shipment.
The USA, of course, with a globe leading number of State variations, has multiple “size matters” classifications. There’s the ‘we don’t care for criteria’ Hazardous Substance list. Lots of readers just thought “RQ” and if you didn’t think “RQ” upon reading “Hazardous Substance”, you should. Some of the materials on the RQ list are completely non-regulated, non-DG below their Reportable Quantity, but a Class 9, Environmental Hazardous Substance at or above their RQ. And combustible liquids are regulated as HazMat for “bulk shipments” but not for the smaller “non-bulk” shipments. What is an SDS author to put in Section 14, “sometimes its DG and sometimes it ain’t”? Hey, that statement’s true, and the determining factor is size.
Sometimes I stray from my Porch Swing, to ridiculously cold environments, from which I am usually eager to jump on an airplane and return home. Today is such an occasion, and this month’s column would probably be more accurately titled “ From the Airplane Seat”. Next to me, a woman just wiped down her seat, seat belt and tray with an alcohol wipe (yes, when she offered me one, I did the same). The wipe was about the size of my hand with spread fingers and I’m sure it qualified for the Solids Containing Flammable Liquid, UN3175 special provision to ship as non-DG when individually packaged. But, I’ve also worked for a company that sells individually wrapped alcohol wipes for clean rooms that are too big (wetted with too much alcohol) to qualify for that same special provision. So, if I have one SDS for the various sizes of my individually wrapped alcohol wipes, what do I put in Section 14? Do I say some are DG and some are not? Am I obligated to explain why? Do I put in the root or intrinsic UN3175 classification and later see the smaller size that shipped in plain, brown boxes held up at the airport because they don’t say UN3175 on them? Oh, please don’t suggest I need separate SDS’s for them, as it either costs too much or my authors are already swamped with work, or both.
There are more examples, but let’s just finish up with elevated temperature materials. Sure this isn’t just an intrinsic property classification issue, and is a ‘condition of transport’ classification, but it is also a Size Matters classification issue. Whether a Class 3 or a Class 9, size is a part of the “hot” classification criteria, with the same Section 14 issues as the other examples.
I am not working much as a shipper myself these days, but lots of my training customers are reporting an increase in carriers, of all modes, not just air carriers, asking for current SDSs and then rejecting or delaying shipments when Section 14 doesn’t exactly match the shipping papers and package marks & labels. What if those rejections aren’t really justified, because a ‘size matters’ classification is involved?
And, gosh, we haven’t hit on maximum size to be a UN1950 aerosol, or how dust diameter can affect 6.1 classifications, or how metal powder can have different properties than metal grains. I’d really like for bigger to be better, especially regarding the size of my belly. But without any value judgments or comparisons of relative merit, I do know one thing unequivocally about transport classifications.
Written 10/21/2014 for HCB Magazine