The Question on FORMIC ACID Flashpoint

Ever since entry for Formic Acid came into IMDG Code as UN 1779, Class 8 subsidiary risk Class 3, FORMIC ACID with more than 85% acid, by mass, the confusion on flash point is tagging along.

 Formic acid, 85% lab reagent grade. Appr. 25 ml of acid. Author W. Oelen
Formic acid, 85% lab reagent grade. Appr. 25 ml of acid.
Author W. Oelen

Some Shippers offer UN 1779 8/3 FORMIC ACID with flash point above 60 Deg C.c.c. and Shipping Line’s Dangerous Goods Safety Approvers reject the request to load asking clarification.

Some Dangerous Goods Safety Approvers do accept to load UN 1779 with flash point above 60 Deg C.c.c considering the fact though FP is above 60 it is not deteriorating safety as per Document of Compliance and SOLAS Chapter II-2., (CONSTRUCTION – FIRE PROTECTION, FIRE DETECTION AND FIRE EXTINCTION).

As per classification of IMDG Code upper limit of flash point for liquids which are to be classified as Class 3 or Subsidiary Risk 3 stops at 60 Deg C.c.c. and shippers offer UN 1779 Class 8/3 with FP above 80 Deg C.c.c.

Table for Formic Acid Concentration v/s Flashpoint
formic acid conentration and flashpoint table
formic acid concentration and flashpoint table

Adding to confusion is missing special provision 223 for UN 1779; however using UN 3412 depending on the concentration, flash point and applying chapter 2 of model regulation for selection of Proper Shipping Name shippers can reach to correct classification for their product.

SOLAS Chapter II-2 & IMDG Code

SOLAS Chapter II-2 Regulation 19 is about Carriage of Dangerous Goods. The purpose of this regulation is to provide additional safety measures in order to address the fire safety objectives for ships carrying dangerous goods.

Due to changes in IMDG Code the said chapter of SOLAS also underwent certain changes.

These changes are made by Maritime Safety  Committee RESOLUTION MSC.269(85) and came into effect from 1st Jan 2011.

Applicable to :

  1. New Ships – keel laid on or after 1st Jan 2011
  2. Existing ships must comply to the changes during the first renewal survey after 1st Jan 2011
  3. Cargo ships of 500 GRT or more and passenger ships constructed on or after 1st Sept 1984
  4. Cargo ships of less than 500 GRT constructed on or after 1st Feb  1992
  • Class 2.3 now divided into 2.3 and 2.3 with subsidiary risk 2.1
  • Lower flashpoint range for flammable liquids changed from ≤ 23°C to FP < 23°C
  • Upper limit of flashpoint is changed from FP 61°C to FP 60°C
  • Class 4.3 is divided into 4.3 Solids and 4.3 Liquids
  • Class 8 having a flashpoint FP ≥ 23°C and subsidiary risk of 6.1 need an additional bilge system as per regulation II-2/19.3.5
  • Class 9 which may emit flammable gas – electrical equipment must be of certified safe type of at least IIB T4, IP55.

 The Document of compliance for the carriage of dangerous goods as per regulation II-2/19.4 of the SOLAS Convention will be replaced for existing ships during next class renewal.

 Table 19.3 is replaced by the following table:

Notes below

11 When .mechanically-ventilated spaces. are required by the IMDG Code.

12 Stow 3 m horizontally away from the machinery space boundaries in all cases.

13 Refer to the IMDG Code.

14 As appropriate for the goods to be carried.

15 FP means flashpoint.

16 Under the provisions of the IMDG Code, stowage of class 5.2 dangerous goods under deck or

in enclosed ro-ro spaces is prohibited.

17 Only applicable to dangerous goods evolving flammable vapour listed in the IMDG Code.

18 Only applicable to dangerous goods having a flashpoint less than 23ºC listed in

the IMDG Code.

19 Only applicable to dangerous goods having a subsidiary risk class 6.1.

20 Under the provisions of the IMDG Code, stowage of class 2.3 having subsidiary risk class 2.1

under deck or in enclosed ro-ro spaces is prohibited.

21 Under the provisions of the IMDG Code, stowage of class 4.3 liquids having a flashpoint less

than 23ºC under deck or in enclosed ro-ro spaces is prohibited.