With many questions regarding the shipment of aerosols and spray products in accordance with transportation laws, we have researched and found the answers to properly doing so.The Department of Transportation, or D.O.T., has a classification called Title 49 CFR, which details these shipments of hazardous materials. UPS, FedEx, and other shipping providers follow these D.O.T. stipulations. The US Postal Service has their own regulations, however as far as shipping aerosol sprays, they are in accord with the same procedures as the D.O.T.
FedEx was contacted at various times, however their representatives seemed to have differing opinions on the methods for shipping aerosol sprays. All agreed that the product(s) must have proper inner wrapping and a sturdy outer box. Yet their labeling of these packages varied. One stated that she did not believe any labeling was needed and another said to just mark it as a Hazardous Material without providing where or how to do so on the package.
After a lengthy conversation with a representative for the Department of Transportation, we have found the clear method for shipping aerosol spray cans. The examples we discussed to reference could be a 17.5 oz. can of dust cleaner, ant killer, paint, window cleaner, or WD-40. The first thing to understand is that aerosols such as these are considered “Consumer Commodities” in Title 49 CFR under their tables, definitions, and procedures in sections 172.101, 171.8, and 173.144. This classification presents exceptions from many of the requirements. For instance, as a Consumer Commodity these aerosols do not require training for Hazardous Material shipping.
The first step in shipping such aerosol spray cans is to suitably wrap the aerosol(s) for the inner package; as mentioned earlier this is done best with simple bubble wrap. The inner package should then be placed in a strong outer package that does not have any specified requirements; and each package may not exceed 66 lbs.
The next key step is properly labeling the packaging. The D.O.T. made it very clear that whenever shipping hazardous materials it is very important to label with the proper shipping name. In this case you need to label your package: Consumer Commodities ORM-D shipping class. The ORM means Other Regulated Materials, and the D is the packaging group. This has now changed to a Limited Quantity label and is just black and white. Upon contacting the UPS Hazardous Materials Department, they suggested that this label be placed near the location of the shipping address so that it is most likely to be seen by the carrier. No other marking, labeling, or hazardous paperwork is required, and the package must be shipped via Ground transportation. The labels must NOT wrap around any edges of the box.
One thorough, important resource is GPO Access at ecfr.gpoaccess.gov. This site provides electronic access, free of charge, to informational products by the Federal government and is a service of the U.S. Government Printing Office. Here Title 49 CFR can be found in its entirety.
Another important factor to the shipment of aerosols is mixing the contents. According to GPO Access, regarding Title 49 CFR, “hazardous materials may not be packaged or mixed together in the same outer packaging with other hazardous or non-hazardous materials if such materials are capable of reacting dangerously with each other and causing” any of the following:
- Combustion or dangerous evolution of heat
- Evolution of flammable, poisonous, or asphyxiant gases
- Formation of unstable or corrosive materials
Although shipping these Consumer Commodity aerosols does not require training, there have been frequent questions about Hazardous Material training for shipping other ORM-D materials. UPS, FedEx, nor any other carriers require training. It is required by the D.O.T. and is listed under Title 49 CFR section 172.74 where the training can be performed by yourself. All you need to have is a documented record of the following:
- Hazmat employee name
- Training date
- Copy of the training materials
- Name and address of person providing training (This can be yourself)
- A certificate showing the employee is trained. (This can be made in house)
A description of this training can be found at hazmat.dot.gov under rules and regulations. The key part of the in-house training is you don’t have to pay someone to train you. Just read this section and put together the emergency contacts, and procedures in case there is an issue. Easy stuff. With that, anyone can ship ORM-D materials effortlessly and correctly.
Key resources for these aerosol spray can shipping guidelines included UPS, through their Hazardous Materials Department at 800-554-9964; FedEx 800-463-3339 through Dangerous Goods; USPS local locations; the Department of Transportation Classification Division at 800-467-4922; GOP Access on line at ecfr.gpoaccess.gov; and the Office of Hazardous Materials Safety on line at hazmat.dot.gov where all the documentation is listed. It is important to understand the correct and proper way to ship aerosol spray products. Please pass on this valuable information and add any comments below.