Paint Shipping Disclosure

Rules, Laws and Regulations for Shipping Paint

The United States Department of Transportation ("DOT") classifies paint as a dangerous good. Other similar products designated as dangerous products include aerosol spray, batteries, butane, lighters, solvents, and many other products. This means it has shipping restrictions requiring ground delivery.

Federal law and regulation is unbelievably complex, obtuse, and difficult to read and navigate a spaghetti-type network of dense rules. Typically, to be cautious paint shippers will typically use ground transportation. Next day delivery making use of air transport may not be available.

Carriers like FedEx may not allow your paint provider to ship paint via their aircraft. One reason is that they often send packages on passenger aircraft, where shipping paint and other hazardous material is much more restricted than shipments on cargo only aircraft.

Title 49 of the Federal Code of Regulations, Section 172.101, lists paint as a Class 3 Hazardous Material. It has a Packing Group Designation of II, and identification number of UN1263. Special designations associated with paint per section 172.102 include that it is poisonous if inhaled. The DOT Hazardous Materials Regulations regulate how dangerous goods can be shipped.

The regulations define "dangerous goods" as substances or materials that are capable of posing an unreasonable risk to health, safety or property when transported in commerce. This includes products that are either flammable, combustible, explosive, corrosive, poisonous, infectious, oxidizing, radioactive, or which are a compressed gas.

Sections 173.101 and 173.27 regarding shipment by aircraft indicate that only up to 1 liter of paint may be shipping on a passenger aircraft or passenger train, and only up to 30 liters by cargo only aircraft. Although your paint shipment may be a smaller quantity, one obvious problem for a carrier is knowing in the aggregate how much is being shipped.

Additionally, for air shipment special shipping containers are required that need to be pressurized, be made up of certain materials, be able to withstand drop tests, and so on. Needless to say, no one wants an aerosol paint container to explode due to pressure changes and to cause a larger fire on an aircraft. Improperly packaged paint can leak due to air pressure changes, causing an additional hazard on an aircraft. Spills and leaks of paint create a fire risk.

This is not a minor legal issue. Fines can be up to $27,500 for each violation plus criminal liability. According to the National Paint and Coatings Association, some have been fined more than $100,000 for violating air shipment rules for paint.

Although you are anxious to get your paint, please do not ask your paint provider to ship any faster than legally allowed. Ground delivery of paint helps keep the product reasonably inexpensive and is the safest method of transporting the product.

Bottom Line: For legal and safety issues your paint will probably be shipped by ground transportation.


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