Question: How do I classify a product that contains methanol as the only dangerous good?
Answer: As per Section 2.3 of the TDG Regulations, when the name of a dangerous good is shown in Schedule 1, that name and the corresponding data for that shipping name (class, subsidiary class(es), packing group (PG)) must be used. Therefore, when methanol is the only dangerous good in the product and it meets the criteria for Class 3, Flammable Liquids, it should be transported as UN1230, METHANOL, Class 3 (6.1), PG II. Note that PG II is the only packing group available for methanol as per Schedule 1 of the TDG Regulations.
Note: Subparagraph 1.3(2)(d)(iv) of the TDG Regulations allows a person to indicate the word “SOLUTION” or “MIXTURE” and also the concentration of the solution or mixture after the shipping name, as applicable.
For any questions related to the classification of a product, contact: TC.TDGClassification-ClassificationTMD.TC@tc.gc.ca
Question: Tests results for a solution containing methanol as the only dangerous good indicate that its packing group should be III. How do I choose the proper shipping name?
Answer: Even if a dilution would lead to a change in packing group (PG) from PG II to PG III, methanol must be transported as UN1230, METHANOL, Class 3 (6.1), PG II because:
- The diluted solution still meets the criteria for Class 3, Flammable Liquids, as per Paragraph 2.18(1) (a) of the TDG Regulations;
- Section 2.3 of the TDG Regulations specifies that, when the name of a dangerous good is shown in Schedule 1, that name and the corresponding data for that shipping name (class, subsidiary class(es), PG) must be used; and
- PG II is the only packing group available for methanol as per Schedule 1 of the TDG Regulations.
Therefore, despite the fact that methanol solution meets the criteria for PG III, the classification of methanol must remain UN1230, METHANOL, Class 3 (6.1), PG II.
For any questions related to the classification of a product, contact: TC.TDGClassification-ClassificationTMD.TC@tc.gc.ca
Question: How does Special Provision 43 apply to the classification of a substance including UN1230, METHANOL?
Answer: UN1230, METHANOL is assigned to Subsidiary Class 6.1, Toxic Substances, based on human experience and not based on numerical data. As such, a person cannot remove Subsidiary Class 6.1 from its classification. As long as the substance has a flash point low enough to meet a Class 3, Flammable Liquids, then Subsidiary Class 6.1 has to be shown. Therefore, test results or calculation method cannot be used to discard the toxic subsidiary hazard of the mixture or solution.
For any questions related to the classification of a product, contact: TC.TDGClassification-ClassificationTMD.TC@tc.gc.ca
Question: How do I classify a product that contains a mixture of methanol and another dangerous good?
Answer: Scenario – Methanol mixed with a Class 8, Packing Group (PG) II dangerous good
As per Section 2.5 of the TDG Regulations, if a substance meets the criteria for inclusion in more than one class or PG, the substance is dangerous goods and its classification is determined in the following manner:
- The classes in which the dangerous goods are included are ranked in order of precedence in accordance with Section 2.8 to determine the primary class and the potential subsidiary class or classes;
- The potential PG is the one with the lowest roman numeral;
- The shipping name in Column 2 of Schedule 1 that most precisely describes the dangerous goods and for which the corresponding data in Columns 1, 3 and 4 are the most consistent with the primary class, the potential subsidiary class or classes and the potential PG is selected; and
- The shipping name and the corresponding data in Columns 1, 3 and 4 of Schedule 1 are used as the classification of the dangerous goods
For example, a mixture containing methanol and meeting the requirements of:
- Class 3, PG II
- Class 8, PG II
As per the table of precedence of classes found in Section 2.8 of the TDG Regulations, Class 3 would be the primary class of this mixture. Furthermore, since the mixture contains methanol and meets the criteria for a Class 3, Flammable Liquids, the Subsidiary Class 6.1 must be shown. Therefore, the shipping name for this dangerous good would be:
- UN3286, Flammable Liquid, Toxic, Corrosive, N.O.S. Class 3 (6.1, 8), PG II
Note: UN1230, METHANOL is assigned to Class 6.1, Toxic Substances, based on human experience and not based on numerical data. As such, a person cannot remove Subsidiary Class 6.1 from its classification.
For any questions related to the classification of a product, contact Transport Canada
For clarification or questions on other TDG-related items, contact:
Mr. Tracey Thibeau CSS
Senior Safety Advisor
Danatec Educational Services Ltd.
501 Palisades Way, Unit 202
Sherwood Park, AB T8H 0H8
Cell: 780 298 9544
Toll-Free: 1 800 465 3366
Email: tthibeau@danatec.com
www.Danatec.com.
Comments are closed.