[Nhcoll-l] Formaldehyde and IATA
Dirk Neumann
Dirk.Neumann at zsm.mwn.de
Tue Jun 11 05:25:09 EDT 2013
Hi Lars Erik!
the 10-15 % formaldehyde solution refers to the wording in the IATA
handbook. I tried to be very careful with my wording, but it seems that
we got again lost in this formalin/formaldehyde solution confusion.
Sorry for this.
The ICAO and IATA restrictions refer to a formaldehyde solution not
stronger then 10 % gas in solution.
For the methanol, I have the impression that the restrictions aims to
regulate the methanol fumes that could build explosive gas mixtures, if
the methanol concentration in a provided liquid is too high (because of
the high evaporation rate of the methanol). However, this is very hard
to quantify, as building of such flammable gas mixtures strongly depends
on the temperature (which is unpredictable in the belly compartments or
air lines). You would also need to consider the total amount of fluid
that would be contain a critical mass/volume of methanol - no reference
in the handbook.
Here, ICAO/IATA regulations would have to go into thermochemical
details, which surely is not the case (and not applicable in practise).
For my understanding, ICAO & IATA want to rule out any ambiguities, thus
introducing regulation on UN2209 and UN1198, making sure, that the
(potential) methanol issue is definitely covered, because the shipper is
held liable that he meets the ICAO/IATA restrictions. You can find more
of these weak definitions in the regulations.
For my understanding, UN1198 would refer to formaldehyde solutions that
are stabilised with even higher (above usual industrial norms) methanol
concentrations, and therefore would not apply for the methanol buffered
formalin we buy and use.
Regarding the 10-25 % formaldehyde solutions, it seems that only these
are regulated (under UN3334) at the moment, and you could only offer
these as limited quantity (requiring an full IATA training &
certification). But as we rarely have the need to ship specimens fixed
in formaldehyde solutions above 4-10%, we should be fine ... at least
this would be mine interpretation of the questioned IATA regulations.
All the best
Dirk
Am 11.06.2013 10:09, schrieb Lars Erik Johannessen:
> Hi again,
>
> I'm a litle confused about which concentrations you refer to Dirk;
>
> In your first paragraph it is evident that you talk about a 27%
> FORMALIN concentration (=10% FORMALDEHYDE). But in the next paragraph
> I read you as you readily carry 10-15% FORMALDEHYDE (=27-40% FORMALIN)
> in your checked luggage, while you would not want to carry a 27%
> FORMALIN solution (=10% FORMALDEHYDE)...?
>
> As far as I can understand these two pieces of information does not
> fit together? My guess is that what you DON'T want to carry is a 27%
> FORMALDEHYDE solution (=73% formalin)? WHich I certainly would agree
> in ...:-)
>
> Perhaps I am overly into the details now, but then also this whole
> formalin/formaldehyde issue is all about details I guess...;-)
>
> Regarding the flammability of methanol, an alternative to do your own
> tests could be to check out the "Lower explosive limit" (LEL) on some
> web site, e.g. one of these:
> http://www.engineeringtoolbox.com/explosive-concentration-limits-d_423.html
>
> http://en.wikipedia.org/wiki/Flammability_limit
>
> As can be seen there, LEL for methanol is 6.7%. If the concentrated
> formaldehyde solution is buffered with 10% methanol, any dilutions
> below 6.7/10 * 37 = 24.8% FORMALDEHYDE (=67% FORMALIN) should be
> non-flammable in my understanding.
>
> BUT I have another question regarding the classification of formalin.
> Reading the 2013 DGR manual, and given that my calculation/definition
> of "flammable" above holds true, I can't see any difference between
> the entries for UN2209 and UN1198;
>
> UN2209 Formaldehyde solution with no less than 25% formaldehyde
> UN1198 Formaldehyde solution, flammable
>
> as, in my understanding, a flammable formaldehyde solution would need
> to be 25% or stronger. Do I get something totally wrong here?
>
> And finally, a questions regarding A180: under A180 one can ship
> formalin solutions with >25% formaldehyde (UN1198), while solutions
> with <10% formaldehyde can be shipped freely irrespective of A180, as
> it is not regulated by DGR.
> But what about 10-25% formaldehyde solutions? As far as I understand
> the DGR manual one will need ADR certification for this, as it is to
> be classified as UN3334, which is NOT covered by A180. Any comments on
> this?
>
> Sorry to bother you guys with these comments & questions, but I
> sometimes find it really hard to understand the exact meaning of the
> DGR manual...!
>
> Regards,
> Lars Erik
>
> On 11.06.2013 08:40, Dirk Neumann wrote:
>> Hi all,
>>
>> I agree with Lars Erik that the allowed concentration of < 10%
>> formaldehyde [gas] in solutions (without further specification of
>> "solution") would be the equivalent of a 27% (aqueous) formalin solution
>> (without wanting to start a new discussion on the 4% formalin /
>> formaldehyde paradox here ;-), however, I would abstain from carrying a
>> diluted 27% (strong) formalin solution in the hand luggage and surely
>> would seal it for the checked luggage in PE foil and would place the
>> bottle in a UN-conform dangerous good packing, e.g. an approved plastic
>> drum, to avoid any troubles in case of leakage.
>>
>> We do carry our (buffered) ~ 10-15 % formaldehyde solution for field
>> work in the checked luggage. The reason why I would not want to carry a
>> 27% strong solution is that this still is a very strong solution, and
>> you - and the person at the airline / airport security that intercepted
>> you / inspected your luggage - have no chance to proof that the
>> concentration is within the limits, unless the 27% stock solution - at
>> the moment of discovery - is still in a sealed original packing that
>> agrees with your specifications. So you always need to argue, and at
>> some airports / countries you should have goods arguments to be able to
>> continue your journey (with your luggage).
>>
>> Your question about the methanol buffer, Mariko, can be answered very
>> easily, and I would like to refer to a very intuitive test that John
>> Simmons recommends to "test" for the concentration of alcohol/ethanols
>> (above 40% or below): try to inflame your solution.
>>
>> If it would burn, then the formaldehyde solution would be considered
>> (and regulated) as *formaldehyde solution, flammable* under UN1198 but
>> would fall out of the ICAO/IATA regulations if you meet the packing
>> restrictions of Special Provision A180.
>>
>> For non flammable formaldehyde solution (that can include traces
>> methanol for stabilisation and buffering), Special Provision A189 for
>> concentrations below 10 % formaldehyde gas in solution applies.
>>
>> If you have to / want to carry a 10 % formaldehyde solution in your
>> checked luggage, I would recommend to carry respective information about
>> the concentration (as detailed as possible) with you, that could proof
>> your specification if required.
>>
>> Hope this helps,
>> all the best
>>
>> Dirk
>>
>>
>> Am 07.06.2013 20:22, schrieb Mariko Kageyama:
>>> Hello dangerous goods regulation experts (off-line the listserv):
>>>
>>> I have a trivial question in relation to this topic of discussion. I
>>> understand that commercially available formalin aquatic solution
>>> contains approximately 37% formaldehyde but it also contains about 10%
>>> methyl alcohol. We usually dilute it with H2O to prepare what is
>>> called 10% formalin as a fixative, containing about 3.7% formaldehyde
>>> and ~1% methyl alcohol. So technically "10% formalin" solution as a
>>> fixative contains a trace amount of flammable liquid. Does it mean
>>> that both Special Provisions A189 and A180 "Not Restricted" apply to
>>> specimens preserved in small quantities of "10% formalin" or we should
>>> not worry too much about the presence of trace amount of methanol in
>>> formalin aquatic solutions and say SP A189 not restricted? For the
>>> purpose of making this question simple, only 10% formalin (3.7%
>>> formaldehyde solutions) is addresed here but you are welcome to give
>>> me advice on formaldehyde solution of different strength (10 ~ 25 ~
>>> 100%). Please correct me if I misinterpret the point completely.
>>>
>>> Thanks a lot for any help in clarification and interpretation of the
>>> complex regulations!
>>>
>>> Mariko
>>>
>>> Mariko Kageyama
>>> Denver, Colorado
>>>
>>> ----- Forwarded Message -----
>>> *From:* Lars Erik Johannessen <l.e.johannessen at nhm.uio.no>
>>> *To:* nhcoll-l at mailman.yale.edu
>>> *Sent:* Thursday, June 6, 2013 12:52 PM
>>> *Subject:* Re: [Nhcoll-l] Formaldehyde and IATA
>>>
>>> Hi,
>>>
>>> I believe a clarification might be in place regarding
>>> concentrations of formalin/formaldehyde:
>>>
>>> 100% formalin is a saturated water solution that contains 37%
>>> formaldehyde by mass. This is also referred to as "37% formaldehyde".
>>>
>>> As the entry in the IATA DGR refers to "formaldehyde solutions" (i.e.
>>> NOT formalin), the following classification of formaldehyde
>>> solutions/formalin should apply:
>>>
>>> <10% formaldehyde = ca. 27% formalin:
>>> Not subject to the IATA DGR regulations
>>>
>>> 10-25% formaldehyde = ca. 27-68% formalin:
>>> Classified as UN 3334
>>>
>>> >=25% formaldehyde = >= ca. 68-100% formalin:
>>> Classified as UN 2209
>>>
>>> Regards,
>>> Lars Erik
>>>
>>> ----- Forwarded Message -----
>>> *From:* Dirk Neumann <Dirk.Neumann at zsm.mwn.de>
>>> *To:* "Bentley, Andrew Charles" <abentley at ku.edu>
>>> *Cc:* "nhcoll-l at mailman.yale.edu" <nhcoll-l at mailman.yale.edu>
>>> *Sent:* Thursday, June 6, 2013 9:09 AM
>>> *Subject:* Re: [Nhcoll-l] Formaldehyde and IATA
>>>
>>> .... just to add:
>>>
>>> A189 _does not_ include any marking requirements, consignments _need
>>> not to be marked_ as required for parcels containing ethanol specimens.
>>> However, *your shipping docs should detail the concentration*
>>> including the phrase *"A189, not restricted" **
>>> *
>>> The wording "not restricted" proofs that:
>>>
>>> 1) you know the regulation
>>> 2) you did check the content offered for transportation and
>>> 3) the material complies with the IATA regulations
>>>
>>> Thanks for your help with this, Andy!
>>>
>>> Dirk
>>>
>>> On 06.06.2013 16:43, Bentley, Andrew Charles wrote:
>>> > Hi all
>>> >
>>> > It was recently brought to my attention by Dirk Neumann that the
>>> entry
>>> > for formaldehyde in the dangerous goods table of the latest IATA
>>> manual
>>> > (version 54) has been amended to exclude the phrase “Formaldehyde
>>> > solution with >10% but <25% formaldehyde” as in the below screenshot
>>> > from the old manual:
>>> >
>>> > cid:image001.png at 01CE5B89.F8A0AD90
>>> <mailto:image001.png at 01CE5B89.F8A0AD90>
>>> >
>>> > This obviously affects our ability to ship dilute formalin solutions
>>> > with specimens – what we call 10% which is actually 3.7%.
>>> >
>>> > I emailed my contact at IATA and he informed me that it was removed
>>> > after some discussion at the last Dangerous Goods meeting but in its
>>> > place a special provision SP A 189 was added which states:
>>> >
>>> > -----------------------------------------
>>> >
>>> > *A189 *Except where the defining criteria of another class or
>>> division
>>> > are met, concentrations of formaldehyde solution:
>>> >
>>> > (a) with 10% or more, but less than 25% formaldehyde must be
>>> classified
>>> > as UN 3334 Aviation regulated liquid, n.o.s.; and
>>> >
>>> > (b) with less than 10% formaldehyde are not subject to these
>>> Regulations.
>>> >
>>> > ----------------------------------------------
>>> >
>>> > So, it appears as if status quo has been maintained, just in another
>>> > way. Solutions of 3.7% formalin are still exempt from the dangerous
>>> > goods regulations and can be transported internationally by
>>> courier as
>>> > before. By definition, as it is outside the scope of the dangerous
>>> > goods regulations and is not classified as an aviation regulated
>>> liquid,
>>> > it can also be carried onto a plane as checked and carry on
>>> (subject to
>>> > TSA regulations) baggage.
>>> >
>>> > Hope that helps
>>> >
>>> > Andy
>>> >
>>> > A : A : A :
>>> > }<(((_°>.,.,.,.}<(((_°>.,.,.,.}<)))_°>
>>> > V V V
>>> > Andy Bentley
>>> > Ichthyology Collection Manager
>>> > University of Kansas
>>> > Biodiversity Institute
>>> >
>>> > Dyche Hall
>>> > 1345 Jayhawk Boulevard
>>> > Lawrence, KS, 66045-7561
>>> > USA
>>> >
>>> > Tel: (785) 864-3863
>>> > Fax: (785) 864-5335
>>> > Email: abentley at ku.edu <mailto:abentley at ku.edu>
>>> <mailto:abentley at ku.edu <mailto:abentley at ku.edu>>
>>> >
>>> > http://ichthyology.biodiversity.ku.edu
>>> <http://ichthyology.biodiversity.ku.edu/>
>>> > <http://ichthyology.biodiversity.ku.edu/>
>>> >
>>> > SPNHC President-Elect
>>> >
>>> > http://www.spnhc.org <http://www.spnhc.org/>
>>> >
>>> > : :
>>> > A : A : A :
>>> > }<(((_°>.,.,.,.}<(((_°>.,.,.,.}<)))_°>
>>> > V V V
>>> >
>>> >
>>> >
>>> > This body part will be downloaded on demand.
>>> >
>>>
>>> --
>>> Regards,
>>> Lars Erik
>>>
>>> -----------------------------------------
>>>
>>> Dr. Lars Erik Johannessen
>>> Head engineer
>>> DNA Bank
>>>
>>>
>>> Natural History Museum
>>> Department of Technical and Scientific Conservation
>>> University of Oslo
>>> P.O. Box 1172 Blindern
>>> NO-0318 Oslo, Norway
>>>
>>> Phone: +47 22851801
>>>
>>> Courier address:
>>> DNA Bank
>>> Natural History Museum
>>> University of Oslo
>>> Att.: Lars Erik Johannessen
>>> Sars gate 1
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>>> Norway
>>>
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>>
>>
>> --
>> Dirk Neumann
>>
>> Tel: 089 / 8107-111
>> Fax: 089 / 8107-300
>> email: Dirk.Neumann(a)zsm.mwn.de
>>
>> Postanschrift:
>>
>> Staatliche Naturwissenschaftliche Sammlungen Bayerns
>> Zoologische Staatssammlung München
>> Dirk Neumann, Sektion Ichthyologie / DNA-Labor
>> Münchhausenstr. 21
>> 81247 München
>>
>> Besuchen Sie unsere Sammlung:
>> http://www.zsm.mwn.de/ich/
>>
>> ---------
>>
>> Dirk Neumann
>>
>> Tel: +49-89-8107-111
>> Fax: +49-89-8107-300
>> email: Dirk.Neumann(a)zsm.mwn.de
>>
>> postal address:
>>
>> Bavarian Natural History Collections
>> The Bavarian State Collection of Zoology
>> Dirk Neumann, Section Ichthyology / DNA-Lab
>> Muenchhausenstr. 21
>> 81247 Munich (Germany)
>>
>> Visit our section at:
>> http://www.zsm.mwn.de/ich/
>>
>
--
Dirk Neumann
Tel: 089 / 8107-111
Fax: 089 / 8107-300
email: Dirk.Neumann(a)zsm.mwn.de
Postanschrift:
Staatliche Naturwissenschaftliche Sammlungen Bayerns
Zoologische Staatssammlung München
Dirk Neumann, Sektion Ichthyologie / DNA-Labor
Münchhausenstr. 21
81247 München
Besuchen Sie unsere Sammlung:
http://www.zsm.mwn.de/ich/
---------
Dirk Neumann
Tel: +49-89-8107-111
Fax: +49-89-8107-300
email: Dirk.Neumann(a)zsm.mwn.de
postal address:
Bavarian Natural History Collections
The Bavarian State Collection of Zoology
Dirk Neumann, Section Ichthyology / DNA-Lab
Muenchhausenstr. 21
81247 Munich (Germany)
Visit our section at:
http://www.zsm.mwn.de/ich/
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