Not Regulated due to De minimis Exceptions

I had a customer ask me to design a safety data sheet for them and to ship their product “Not Regulated.” However, their product contained methanol. A very dangerous chemical. Methanol is a chemical substance that has many hazards and has some strict transport regulations, especially Internationally.

Normally, if you were to ship Methanol internationally, it would be shipped as UN1230 METHANOL, Class 3 subsidiary class 6.1 PG II. Whereas in the United States it is merely shipped as UN 1230 Methanol Class 3. There is no subsidiary class 6.1 when shipping in the United States. Basically, the data that comes from Methanol is based on human experience, therefore according to international regulations it is not based on numerical data.

However, there are certain exceptions to current regulations. According to CFR 49 § 173.4b De minimis exceptions, you can send your product “Not regulated” and do not require shipping information. This can be done provided:

the material is a Class 3, Division 4.1, Division 4.2, Division 4.3, Division 5.1, Division 6.1, Class 8, Class 9, and
the material is limited to 1mL / 1g or less, and
the packaging proves to be capable of absorbing spills, and
it does not react other substances, and
that under no circumstances the material cannot be forbidden from transport in any packaging group

Canada also has similar regulations. This information can be found under Transportation of Dangerous Goods Regulations (SOR / 2001-286) 1.17.1 (8). It simply states:

These Regulations, except for Parts 1 and 2, do not apply to the offering for transport, handling, or transport of dangerous goods in excepted quantities that are assigned to alphanumeric codes E1, E2, E4 and E5 in column 6(b) of Schedule 1 if

the net quantity of the dangerous goods per inner means of containment is less than or equal to 1 g for solids or 1 mL for liquids and gases; and
the net quantity of the dangerous goods per outer means of containment is less than or equal to 100 g for solids or 100 mL for liquids and gases.

Always error on the side of caution when transporting any material, even in small amounts, and check for any applicable regulations or guidelines to ensure safe and compliant shipping. ICC Compliance Center has a team of full-time Regulatory Experts who have years of experience and are certified/recognized in their field of expertise. Ask us your tough questions by calling 888.442.9628 (USA) or 888.977.4834 (Canada) or send us an email.