Classification of Flammable Aerosols Transported to Canada Use of a Packing Group Ⅱ Packaging for a Packing Group Ⅲ Material

摘要

A reader has a flammable aerosol that is authorized under the HMR to be transported as a limited quantity; and has an interest in shipping this aerosol to Canada. Significantly, this aerosol contains a PG Ⅲ Division 6.1 toxic liquid (methylene chloride). Quite possibly the aerosol is used by professionals for degreasing. Under the HMR, the relevant entry is UN 1950 Aerosols, flammable, Div. 2.1. For this entry, the Hazmat Table refers to Special provision "N82" which in turn refers to 173.115 for purposes of classification criteria for flammable aerosols. Under 173.115(1), unlike other flammable gases and liquids, the classification of aerosols as flammable is based on the percentage of flammable contents, heat of combustion, or a performance test evaluating how the expelled contents burn. In the test, the performance of some aerosols is like that of a blow torch. The criteria are more consumer- or workplace-oriented and were negotiated through the coming together of former US and European criteria through the Globally Harmonized Classification System. The complete set of criteria for assigning Division 2.1 to aerosols is set out in Chapter 31 of the UN Manual of Tests and Criteria. There appears to be consistency between the HMR and Canada's Transport Dangerous Goods Regulations (TDGR) which sets out similar criteria in Section 2.14.1(1) - (3).