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Interpretation Response #04-0040 ([University of California, Irvine Environmental Health and Safety] [Mr. Younghans-Haug])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: University of California, Irvine
Environmental Health and Safety

Individual Name: Mr. Younghans-Haug

Location State: CA Country: US

View the Interpretation Document

Response text:

May 11, 2004

Mr. Younghans-Haug                Reference No.: 04-0040
Chemical Safety Programs Specialist
University of California, Irvine
Environmental Health and Safety
4600 Bison Avenue
Irvine, California 92697-2725

This responds to your letter dated February 6, 2004, regarding the classification of formaldehyde solutions under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) and the International Civil Aviation Organization’s Technical Instructions for the Safe Transport of Dangerous Goods by Aircraft (ICAO Technical Instructions).  Specifically, you ask if we agree with your opinion that volumes of thirty (3 0) milliters or less of 10% formaldehyde solutions in an outer package would not create in a cargo-hold aboard aircraft conditions as prescribed under Special Provision “A27” of the ICAO Technical Instructions.

The current HMR and the ICAO Technical Instructions have two entries for Formaldehyde solutions, as follows: “Formaldehyde solutions with not less than 25% formaldehyde, 8, UN 2209, III” and “Formaldehyde solutions, flammable, 3, 8, UN 1198, III”. In the ICAO Technical Instructions, Special Provision “A27” is not specifically assigned to these entries.  The HMR do not contain a Special Provision “A27”.  The quantity (30 milliters) of the Formaldehyde solutions in the outer package is not relevant to classification of the material.

Formaldehyde solutions (10% formaldehyde) do not meet the classification criteria for either of these entries.  However, the acute effects of Formaldehyde solutions have been well documented.  Based on the definition for a Class 9 material in the HMR, it is the opinion of this Office that “10% Formaldehyde solution” meets the definition of a Class 9 material in § 173.140 and is subject to regulation when transported domestically by aircraft.  The appropriate shipping description is: “Other regulated substances, liquid, n.o.s. (Formaldehyde), 9, NA 3082, III” All other applicable rules of the HMR apply.  Shipments of formaldehyde solutions when transported internationally by aircraft must conform to the ICAO Technical Instructions.

For your information, formaldehyde solutions shipped in an inner packaging of 30 milliters or less in accordance with the small quantities exceptions in § 173.4 of the HMR are excepted from marking, labeling, placarding and shipping papers, and emergency response information requirements of the HMR.
I hope this satisfies your inquiry.  If we can be of further assistance, please contact us.


John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards

173.4, and 173.140.

Regulation Sections

Section Subject
173.140 Class 9-Definitions
173.4 Small quantities for highway and rail