American Coatings Association

The United Nations’ Subcommittee of Experts on the Transport of Dangerous Goods (UNSCOE TDG) will convene in Geneva, Switzerland from June 20-24, and will consider some 21 formal papers or proposals germane to hazmat transportation. Particularly salient to industry is a proposal from new UNSCOE TDG member state Korea, in which it proposes a singular primary shipping name, or PSN, for Paint Related Material.

Other papers of interest to the coatings industry include one submitted by the Dangerous Goods Advisory Council (DGAC) on the application of the Air Limited Quantity (LQ), and a paper by the International Air Transport Association (IATA) on the Classification of Class 3 viscous liquids in packing group III.

ACA, as a representative of the International Paint and Printing Ink Council (IPPIC) will support the DGAC Air LQ Mark because it believes this to be a practical solution since it may be unknown if commodity is going by air. IPPIC will also support the IATA proposal for Class 3 viscous liquids in packing group III, as long as the viscosity table for packing group II to packing group III includes the <450 litre exemption.

The Korean proposal addressing the PSN for Paint Related Material stems from the burden of shipping paint and paint thinner in the same box; that is, the matter of marking the package with both PSNs and the shipping paper with both PSNs.

IPPIC believes that the proposal to eliminate “Paint” as a proper shipping name is extremely problematic for several reasons. First, in the UN dangerous goods list in Chapter 3.2 of the Model Regulations on the Transport of Dangerous Goods, “Paint” and “Paint Related Materials” are both assigned to UN 1263 (The proper shipping name of Paint and Paint Related Material also appear in UN 3066, UN 3469 and UN 3470 and are defined in exactly the same manner as UN 1263). Paint is clearly defined as paint, lacquer, enamel, stain, shellac, varnish, polish, liquid filler and liquid lacquer base while Paint Related Material is defined as paint thinning compound or reducing compound. Therefore, shipping both Paint and thinning compound in the same packaging does require use of both proper shipping names on the package and the shipping documents. While this is burdensome, it is necessary (and required under 2.0.2.2) in order to ensure that accurate information about the hazardous material is passed along in the case of an incident.

Moreover, eliminating paint and using Paint Related Material as the PSN does not accurately convey to emergency responders what is inside the packaging. Paint is clearly defined and Paint Related Material is also clearly defined and they are distinct commodities. From a safety standpoint, an emergency responder will respond differently to an incident involving a material that is Paint, than they will to an incident that is mostly a solvent material like Paint Related Material.

IPPIC has crafted a resolution to present at the UN meeting that will hopefully satisfy all parties: a Special Provision which would allow for the use of Paint Related Materials when there is a shipment of packages containing both Paint and Paint Related Materials.

The IPPIC resolution states the following:

(1) Paint is a very high volume commodity that is shipped worldwide. Indeed, 90 percent of UN 1263 in transport is Paint (and not Paint Related Material) and disappearance of Paint as a proper shipping name will cause significant confusion for manufacturers, shippers, carriers, emergency responders, and users of the material.

(2) The time and resources necessary to make the change in information technology systems is significant and the increased costs are not warranted as carriers have not expressed any frustration or problems with the current system.

(3) We note also that UN 1210 Printing Ink is structured similarly to UN 1263 in that it contains two proper shipping names: Printing Ink and Printing Ink Related Material.

(4) In order to relieve the burden of marking a package with Paint and Paint Related Material with both proper shipping names and the shipping documents similarly, IPPIC is suggesting an alternative solution of creating a Special Provision that would allow for option to use Paint Related Materials when a package contains both Paint and Paint Related Materials. This option could be afforded to UN 1263, UN 1210, UN 3066, UN 3469 and UN 3470.

IPPIC believes that this special provision would resolve the issue satisfactorily.