I read recently that the Department of Transportation (DOT) has changed the way that we must classify our products. What has changed and how long do I have to change my packaging if these changes affect the products that I ship?

DOT did recently make two classification revisions – a small change regarding flammable liquids, and a significant revision of toxicity criteria. The final rule, from Docket No. PHMSA–06–25476 (HM–215I), "Hazardous Materials: Harmonization with the United Nations Recommendations, International Maritime Dangerous Goods Code, and International Civil Aviation Organization’s Technical Instructions," revises the Hazardous Materials Regulations to achieve alignment with international standards.

The PG III flammable liquid criteria has been lowered from 141º F (60.5º C) to 140º F (60º C).

The toxicity criteria will cause some materials to be regulated for the first time, and will drop others that were previously regulated completely out of regulation. These altered criteria are outlined below:

Material properties                                                         Current PG                  New PG

Oral LD50 > 200, ≤ 300 (Solid)                                           Not Regulated                     III

Oral LD50 > 300, ≤ 500 (Liquid)                                                III                       Not Regulated

Dermal LD50 > 40, ≤ 50                                                           II                                 I

Inhalation toxicity by dusts and mists LC50 > 0.2, ≤ 0.5             I                                  II

Inhalation toxicity by dusts and mists LC50 > 4, ≤ 10                III                        Not Regulated

You will have plenty of time to review your product classifications and make any necessary changes to your packaging. These amendments were enacted in a voluntary status on January 1, 2007 and technically become mandatory as of January 1, 2008. However, DOT is allowing the continued use of the "old" flammable liquid (Class 3) and toxic materials (Division 6.1) classification criteria and packing group assignments to be used until Jan 1, 2012.

- Rone-iff A. Carr

Mr. Carr is a technical project specialist with 3E Company. He joined 3E Company in 2002 and currently works in the Transportation & Classification department.PROD1PC60 wULES4

Yasmin has garnered more than 25 years of experience with chemical products through her work with various chemical industries in China and Denmark. She also has more than seven years of experience as a consultant in EH&S and regulatory management. She is involved and experienced in global material safety data sheet (MSDS) authoring, labeling, product registrations and other EH&S regulatory management fields. She is responsible for the management of the Ariel's authoring system which includes developing work processes, creation of rules and classification logic for different regions (i.e. EU, Asia-Pacific, NA and GHS). She is also responsible for authoring large amounts of MSDSs for more than 30 countries in more than 20 different languages. She is a great asset with her consulting work with many Asian-Pacific companies concerning Chinese regulations of chemical safety as it relates to MSDSs, registration and transportation. She is also the project manager for several clients providing authoring, global consulting services and EH&S regulatory services especially in Europe and China.

When asked what she likes most about working at 3E Company she replied: "I like working in an international company where I can use my Chinese background to give input for Chinese chemical regulations. I enjoy managing projects, helping our customers worldwide with EH&S compliance and working with such a good team." In her spare time, Yasmin enjoys golf, world travel, and watching action movies.

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