|
Shipping Oil
Lubricant Samples
By Stan Smith
In general, petroleum
based oil lubricant samples are not regulated for shipping within the US.
That is, most lubricating oils are not regulated by the US Department of
Transportation (DOT) or the International Air Transport Association
(IATA). There are certain classes of petroleum oils that may be
regulated by DOT as listed in regulations found at 49CFR172.101, however
this does not apply to the vast majority of typical petroleum based
lubricants are not regulated. It should also be noted that commercial
carriers (e.g., FedEx, UPS, and DHL) may choose to be more restrictive in
their corporate policies than the regulations regarding
transportation. Please consult with your specific carrier for more
details on their particular policies regarding the transportation of
petroleum lubricants.
The United States
Postal Service being its own branch of the US government establishes its
own regulations for the transportation of hazardous materials. Within
the limited scope of petroleum oils, it appears that the USPS has similar
regulations in place to control those petroleum oils that may be considered
hazardous by the DOT. However, it also appears that typical petroleum
based lubricant samples are acceptable for shipment by the USPS.
Regulations can be
difficult to interpret and some companies and agencies may come to
different conclusions based on their interpretation of the regulations,
particularly when concerning a very broad category of materials such as
petroleum oils. As such, it is highly recommended that the Material
Safety Data Sheet (MSDS) associated with the specific lubricant be
consulted for the lubricant manufacturer’s determination of the
applicability of the transportation regulations. For example, the
MSDS for a popular 15W40 engine oil was reviewed
and Section 14, Transportation Information, indicated that Petroleum
Lubricating Oil is not regulated as a hazardous material for transportation
under 49CFR. The MSDS also indicated that Petroleum Lubricating Oil
is not regulated as Dangerous Goods for transportation under IATA.
So, rather than trying
to weed through and interpret the transportation regulations, it is much
easier to simply reference the regulatory info directly from the oil
manufacturer. The customer should have MSDSs
for the products they use as required by OSHA, so they should be able to
provide a copy of the MSDS to the carrier to prove that the sample is
acceptable to ship. Simply let the MSDS speak for itself.
It is
still recommended, if not a requirement of many carriers, to properly
package lubricant samples to prevent oil leaks and spills. Staveley
Services sample packaging consists of two HDPE (other plastics may also be
used) plastic bottles that have screw-on caps to prevent leakage. The
bottle containing the lubricant sample is placed within a slightly larger
mailing container. If any leakage should occur from the inner container,
the secondary bottle will contain it, thus preventing any spills and
shipping interruptions.
|
