Dangerous Goods in Apparatus

Posted:
Thu Jan 03, 2019 5:44 pm
by jdpetey
Does anyone know where I can definitively find the shipping requirements for a fuel injector and a few high pressure pipes?
I have Hazmat Certification per requirements, but haven't had to 'properly' ship anything until lately.
I shipped one injector back without using hazmat successfully, and the next one I received a "We will debit any further parts not properly shipped" letter after the second one.
Thanks in advance
Re: Dnagerous Goods in Apparatus

Posted:
Thu Jan 03, 2019 6:40 pm
by EH427
Must be on the BOL along with verbiage exactly like this for any part that may have gasoline in it.
UN3363,Dangerous goods in apparatus,9,ERG# 171
Also see GM bulletin: #99-00-89-019P
More info below:
Fuel Hazmat Labor ops: this is a living document and may have ops added as new ops are added with Hazmat associated
Hazmat Materials Transportation Codes which shows the correct descriptions, exactly as it needs to be written on the BOL, the hazard code, and the type of box marking. Please note that no other box UN type may be used. Also note that you much have proper labels for all boxes.
WPC Bulletin. This includes information about the Hazmat materials as well as training materials and links that are available to dealerships.
US Engines 49 CFR
There is a website for preparing paperwork via hazmatonline.phmsa.
Re: Dangerous Goods in Apparatus

Posted:
Fri Jan 04, 2019 1:39 pm
by ZOT MOLT
It's been a while since I posted here but I wanted to provide the following:
The following can be found at "phmas dot dot gov" search 15-0243
If you read section A2, the part that says "Provided that the parts are both cleaned and purged in accordance with 173.29(b)(2) to the extent that no residual hazardous material or vapor remain in the part, the part is not subject to the requirement of the HMR."
It is my interpretation that if you can not smell any vapor, the part is no longer considered hazardous. If I was to ship fuel injectors etc. as HAZMAT I may consider using UN3363 Dangerous good in machinery. I am not offering legal advise, just giving my opinion.
Interpretation Response #15-0243
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date: 05-19-2016
Company Name: Environmental Health & Safety Individual Name: Ms.
Location state: TX Country: US
View the Interpretation Document
Response text:
May 19, 2016
Ms.
Environmental Health & Safety
DOT/Hazmat Transportation Compliance
Samsung Austin Semiconductor
12100 Samsung Blvd.
Austin, TX 78754
Reference No. 15-0243
Dear Ms. Winterburg:
This is in response to your recent letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) regarding the appropriate classification for equipment containing the residue of a hazardous material. In addition you ask for clarification of “shipper” responsibilities applicable to vendors operating on-site at your facilities. The tasks performed by these vendors include pre-transportation and transportation functions, storage, cleaning and decontamination of pumps, tools, parts, and other mechanical equipment that may contain processed residue within. Your questions are paraphrased and answered below.
Q1. For the pumps, tools, parts, and other mechanical equipment, the exact amount of hazardous material residue is often not possible to determine and cannot be removed without rendering the equipment unusable. The final residue composition in the equipment is determined by reviewing all the changes produced during the processing of raw materials and gases. You state that the residue is integral to equipment and ask if “UN3363, Dangerous goods in machinery” is the most appropriate classification.
A1. The answer is yes. It is the opinion of this Office that hazardous material residue in components of equipment or machinery may be considered integral if the residue is necessary to the function of the equipment, its removal would cause damage to the equipment, or it performs some other function necessary to the equipment such that it cannot be removed from the equipment while it is in transportation. Please note that the proper shipping names “Dangerous goods in machinery” and “Dangerous goods in apparatus” are appropriate shipping names for components of machinery or equipment that contain residual hazardous materials. Materials prepared for transportation using these proper shipping names must comply with the requirements specified in § 173.222 including the net quantity limitations prescribed in § 173.222(c).
Q2. For parts requiring cleaning, a minor onsite purging process is completed prior to providing the vendor with the part. Upon receipt of the parts by the vendor, the parts are prepared for shipment and transported to the vendor facility where comprehensive maintenance and in-depth cleaning are performed. Once the cleaning is complete, the vendor transports the part back to your facility. You ask for the most appropriate classification of the parts in this scenario.
A2. If the parts are not completely free of the residue of a hazardous material (through a combination of cleaning and/or purging) prior to transport to the vendor facility as described in your letter, then “UN3363, "Dangerous goods in machinery” would be an appropriate description. Provided that the parts are both cleaned and purged in accordance with
§ 173.29(b)(2) to the extent that no residual hazardous material or vapor remain in the part, the part is not subject to the requirements of the HMR.
Q3. When the parts require repair or calibration the process is identical to that described in Q2 with the exception that the parts are processed for repair and calibration, not for in-depth cleaning. You ask for the most appropriate classification of the parts in this scenario.
A3. See A2.
Q4. As the on-site vendor at your facility conducts all of the steps involved in the preparation and actual transportation and delivery of these items described above, you ask if the vendor, the manufacturing facility, or both, are responsible for compliance with the HMR, including the “shipper’s certification” on shipping papers?
A4. Based on your description, the vendor performs all offeror and carrier functions and therefore is responsible for ensuring that the shipments conform to the requirements of the HMR. Specifically, an offeror is responsible for ensuring proper labeling and shipping papers under §§ 172.200, 172.204, and 172.400; and an offeror or carrier (when assigned the function) is responsible for markings and placards under §§ 172.300 and 172.500.
Please note that if your company, the manufacturing facility, performs any pre-transportation functions (as defined in § 171.8) related to the residue shipment, including but not limited to securing the closure on a package, preparing a shipping paper, providing emergency response information, or certifying that a shipment is in proper condition for transportation in conformance with HMR requirements, your company is responsible for compliance with the HMR.
ZOT MOLT.