Case Study – Shipping Carbon Dioxide Cartridges for a Consumer Product

, Case Study – Shipping Carbon Dioxide Cartridges for a Consumer Product, ICC Compliance Center Inc - USA

In a long hot summer, what’s better than a cold drink of fizzy soda? Not much. But of course, there’s a downside. Buying sodas retail can be quite expensive. And that’s not even considering the environmental impact of millions of plastic bottles generated each summer by the thirsty public.

So, I wasn’t surprised when a family member asked for a soda machine for a birthday present. These handy gadgets take water, pressurized carbon dioxide, and various flavors to create your own special brew, or just a pleasant sparkling water if that’s your preference. The cost savings are significant, as well as the environmental benefits. But as I was ordering it, something struck me – those carbon dioxide cylinders called “carbonators.” They’re dangerous goods (technically, they’re classed as UN1013, CARBON DIOXIDE.) So, how exactly do vendors (whether the original companies or third-party refillers) deal with shipping them?

Dangerous Goods Options for Carbonation Cartridges

The machine I settled on for my gift was one of the major makes. These machines can be picked up in stores (subject nowadays to Covid precautions) or ordered online, either direct from the manufacturer or through a third-party online retailer.

Picking one up is the easy way in both the U.S. and Canada. In the United States, the Hazardous Materials Regulations of Title 49, Code of Federal Regulations (49 CFR) only applies to “transport in commerce,” and driving your new soda machine home (or extra carbon dioxide cylinders) doesn’t fall under this heading. 

In Canada, though, the issue is a little more complicated. There, it doesn’t matter whether the shipment was “for hire or reward,” so you wouldn’t be automatically exempted. However, the Transportation of Dangerous Goods Regulations (TDG) provides consumers with section 1.15, the 150 Kilogram Exemption. This allows you to buy consumer products at retail outlets and drive them home (or have the store deliver them using its own vehicles), as long as they are “in a quantity and concentration available to the general public.” There are some restrictions in this exemption, but it will allow the carriage of the carbon dioxide cylinders (as long as the gross weight doesn’t exceed 150 kilograms) without being subject to the normal requirements of TDG. 

But since my family member didn’t live near me, I thought it would be simpler to order online and have the whole thing shipped directly to his home. That meant that the retailer would likely have to use a third-party carrier. This would qualify as “transport in commerce” in the U.S., and in Canada, the shipment wouldn’t be eligible for exemption under section 1.15. 

Would this be feasible? Would I end up having to pay exorbitant dangerous goods shipping fees?

Well, the first option I thought of was the Limited Quantity provision. For ground shipment in both Canada and the U.S., this is always a handy method for shipping small containers of dangerous goods – you just have to keep your inner containers within the authorized size for the substance, make sure each package doesn’t weigh more than 30 kilograms (66 pounds), and mark each package with the diamond-shaped limited quantity mark. This allows safe yet economical shipments, and is used a lot by big online retailers. But I discovered a problem.

A typical carbon dioxide cylinder for the machine in question can range in capacity up to about 1.41 L (48 fluid ounces). (Note that the volume measurement most often cited in the product literature is the quantity of soda the cylinder can produce, not the actual capacity of the cylinder.) If you consult TDG, the limited quantity size for inner containers of carbon dioxide is only 0.125 Litres. In 49 CFR, the issue is more complex, but these cylinders still appear to exceed the authorized limit in section 173.306. So the limited quantity provision is not an option.

The obvious alternative is to send shipments to and from the customer as regular dangerous goods/hazardous materials. But this isn’t a great solution. Not only would it drive shipment costs up for both inbound and outbound shipments, but the consumer would be considered a dangerous goods/hazmat shipper when returning the cylinders for refilling or recycling. They would have to be trained and certified according to their national standard.

So, how to solve this conundrum? Well, it turns out that the manufacturer applied to both governments for permits (called special permits under 49 CFR and equivalency certificates under TDG). Under these, the supplier proposed a rather elegant solution. They would provide consumers and retail outlets with a company-designed packaging kit. It would include a fiberboard overpack with pre-printed safety marks, shipping labels, and a shipping document with as much information as possible already filled in. The kit would come with detailed instructions on how to package the cylinders for transport. All the customer would have to do is contact the manufacturer and have a kit sent to them, then follow the instructions as approved by the special permit/equivalency certificate. They wouldn’t have to be officially trained in dangerous goods transportation.

However, while reading reviews of the machine I decided to purchase, I saw a problem some customers have noted. Many third-party online vendors have refused to accept returns of the machines, citing hazmat concerns. So I’m glad the birthday boy liked the machine and is happy with his refreshing sodas! It’s often better to order directly from the manufacturer who is assured of accepting the return of an unwanted machine.

By the way, users of such machines should remember that these cartridges should not be thrown into the garbage when empty – they’re still hazardous and could explode if mishandled. They can, of course, be refilled if you’re going to keep using the machine. Otherwise, empty carbon dioxide cylinders can be returned to a local retailer, or you can contact the manufacturer’s customer care department for instructions. 

So, the moral of the story is that even common consumer products may pose a hazmat issue. Manufacturers need to keep this in mind when designing and marketing their products, while consumers need to read the fine print and understand their responsibilities for regulated products. If you have any questions about your products, call us here at ICC (888-442-9628 for our U.S. offices, 888-977-4834 for our Canadian offices), and we’ll help you figure out what the requirements are.

Sources:
Transport Canada, Transportation of Dangerous Goods Regulations
Transport Canada, How to Apply for an Equivalency Certificate (Permit of Equivalent Level of Safety)
US Department of Transportation, Hazardous Materials Regulations, 49 CFR
PHMSA (Pipelines and Hazardous Materials Safety Administration), Hazardous Materials Approvals and Permits Overview
Soda Pop Craft, How to Dispose of SodeStream Gas Bottles and Recycle TIPS

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Limited Quantity Labels
Barbara Foster

Barbara Foster

Barbara Foster graduated from Dalhousie University with a Master’s degree in Chemistry and a Bachelor’s degree in Education. As one of ICC Compliance Center’s most senior employees, she has worked in the Toronto office for the past three decades as a Regulatory Affairs Specialist and Trainer. She is fluent in various US, Canadian, and international regulations involving transportation, including TDG, 49 CFR, ICAO, IMDG, and the ADR/RID. She also specializes in the hazard communication standards of OSHA, WHMIS, CCCR, and the Globally Harmonized System for Classification and Labelling (GHS). Barbara is the author of ICC’s TDG Clear Language Driver and Handler’s Guide. Currently, she is a participant on the Canadian General Standards Board committee where she creates training standards for transportation of dangerous goods in Canada and is a past Chair of the Dangerous Goods Advisory Council.

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