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The alcohol

Shipping a flammable liquid

Updated

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There is real relief available, and it is conditioned on numbers your formula decides.

What the exception gives you

Limited quantities of Class 3 flammable liquids are excepted from labeling requirements, unless offered by aircraft, and excepted from the specification packaging requirements when packaged in combination packagings according to the paragraph.

And it goes further

A conforming limited quantity package is not subject to the shipping paper requirements of subpart C, unless the material is a hazardous substance, hazardous waste or marine pollutant or is going by aircraft or vessel, and shipments are not subject to placarding.

The inner packaging limits

For Packing Group I, inner packagings not over 0.5 L each. For Packing Group II, not over 1.0 L each. For Packing Group III and combustible liquids, not over 5.0 L each. In every case packed in a strong outer packaging.

And a cap on the whole package

Each package must conform to the packaging requirements of subpart B and may not exceed 30 kg, which is 66 pounds, gross weight. For 30 mL bottles that is not a practical constraint; for a case of 120 mL bottles in glass it can be.

Your packing group follows from the flash point

Which follows from the concentration. So the inner limit you are working to is a consequence of the formula, and a reformulation upward can move you into a tighter limit without anything else changing.

Air is a different answer

For transportation by aircraft the package must also conform to 49 CFR 173.27, including authorized materials, inner packaging quantity limits and closure securement, and only hazardous material authorized aboard passenger-carrying aircraft may go as a limited quantity.

And the exception is not automatic

It is permitted only if 173.150 is referenced for the specific hazardous material in the 172.101 table. So the first step is the table entry for what you are actually shipping, not the exception itself.

References

49 CFR 173.150, Exceptions for Class 3 (flammable and combustible liquids). Limited quantities are excepted from labeling unless offered by aircraft, and from specification packaging when in combination packagings, with inner packagings not over 0.5 L for Packing Group I, 1.0 L for Packing Group II and 5.0 L for Packing Group III in a strong outer packaging, and no package exceeding 30 kg gross. The exception applies only where this section is referenced for the material in the 172.101 table. law.cornell.edu
29 CFR 1910.1200, Hazard Communication, which sets what a shipped container of a hazardous chemical carries and requires a safety data sheet. law.cornell.edu
Written from federal regulation and from measured catalog data, not from a perfumer’s bench. Whether a formula is Packing Group I, II or III follows from its flash point, and whether the limited quantity exception is available depends on the 172.101 entry for the material. Nothing here is a permit, a classification or a finding that a package complies.