Understanding UN Packaging Standards
Overview
The packaging for the transportation of hazardous materials within the United States is regulated by the U.S. Department of Transportation (DOT). Within the Department of Transportation is The Research and Special Programs Administration (RSPA), which is responsible for establishing the rulemaking procedures and regulations for the transportation of any hazardous material, which includes establishing the non-bulk performance-oriented packaging standards.
In order to achieve a more global perspective and help facilitate the transportation of hazardous materials in international commerce, RSPA has written the Code of Federal Regulations for the transportation of hazardous materials around the United Nations (UN) recommendations. The Title 49, Code of Federal Regulations (49 CFR) defines the minimum packaging standards which allow manufacturers more flexibility in the design and manufacturing of hazardous materials packaging. These standards are designed to encourage packaging innovation by establishing specific minimum performance specifications to which packaging will be tested. Package design engineers can now design hazardous materials packaging through the utilization of the newest technology and materials to produce stronger, more economical packaging for the industry.
The Title 49, Code of Federal Regulations defines the standards for the transportation of hazardous materials within the United States. If a hazardous material is shipped from Canada to South America through the United States via highway or rail, the 49 CFR guidelines must be followed. Other countries or agencies may also have standards that have been established which govern the transportation of hazardous materials within their own jurisdiction. Some of these may differ from the United States
49 CFR and should be considered before transporting hazardous materials into these countries. Examples of these include:
- The Canadian Transportation of Dangerous Goods Act and Regulations.
- The Mexican Regulations of Surface Transportation of Hazardous Materials and Wastes.
- The International Maritime Dangerous Goods Code (IMDG)
- The International Civil Aviation Organization's Technical Instructions for the Safe Transport of Dangerous Goods by Air.
This guide is an abbreviated overview of the Title 49, Code of Federal Regulations for the transportation of hazardous materials*. It is intended to provide a basic, informative look at the requirements necessary for packaging to become "UN certified."
The focus of this guide is on non-bulk packaging standards and explores the testing, marking, and customer notification requirements to provide hazardous materials shippers UN certified packagings.
* This guide is not inclusive of all the information contained within the 49 CFR. To fully obtain all regulation details, exceptions and specific requirements, one should consult the Title 49 CFR book, parts 100 to 185, or contact the RSPA directly at 800-467-4922.
Section I Responsibilities
Packaging manufacturers have specific responsibilities when it comes to meeting 49 CFR requirements. These responsibilities differ from those of a shipper of a hazardous material. To ensure that proper procedures are followed and areas of responsibility are covered, the following defines the packaging manufacturer's responsibilities and the shipper's responsibilities.
Manufacturer Responsibility
- Engineer and manufacture non-bulk packaging to perform to specific packing group performance-oriented standards.
- Qualify packaging to meet UN standards.
- RE-qualify the packaging annually or as required.
- Keep on file copies of all design qualification and periodic re-certification test reports.
- Provide markings on the packaging that identify it as being a UN standard packaging tested for a particular packing group, specific gravity or gross mass, hydrostatic pressure, and other DOT requirements.
- Notify in writing each person to whom the packaging is transferred of the type and dimensions of any closures, including gaskets, needed to satisfy performance test requirements and the proper assembly and closure instructions.
- Retain copies of each written notification for at least one year from the date of issuance and make them available for inspection by a representative of the Department of Transportation.
- Provide hazardous materials general awareness, function specific (if applicable), and safety training to pertinent employees within 90 days of hiring date and properly retrain every three years. Records of training must be kept for at least 90 days after employee's termination and copies of all training records must be kept at each plant or facility.
Hazardous Material Shipper's Responsibility
- Determine the proper shipping name of the hazardous material in question and identify the appropriate hazard class and packing group assignment for material.
- Determine any exceptions or limitations that may apply, based upon the intended mode of transportation.
- Determine whether a specific packaging is qualified to be used for the transportation of the hazardous material including the specific gravity or gross mass to be used as well as any applicable hydrostatic pressure.
- Determine the compatibility of the hazardous material with the packaging material to ensure that chemical resistance exists between the two materials. This includes conducting some long-term storage compatibility tests.
- Complete the assembly of the packaging including any assembly and closure installation per the packaging manufacturer's instructions.
- Label the packaging with the proper hazardous material label as specified in 49 CFR.
- Provide hazardous material training to employees as defined in 49 CFR.
- Provide shipping papers with all of the required elements as defined in 49 CFR.
- Ensure proper placarding requirements for carriers are fulfilled as defined in 49 CFR.
- Have an Emergency Response Plan is place for a hazardous material spill.
Section II Penalties and Fines
In a perfect world, all hazardous materials shippers would easily comply with the DOT regulations because they want to ensure the safety of all living things that could be adversely affected by a hazardous material spill. Unfortunately, this does not take place in the real world.
Most hazardous materials shippers will easily comply with the minimum requirements set forth by the DOT regulations. They are concerned about their own liability in the event of an unfortunate incident or spill. By complying with the minimum requirements, they have shown the proper authorities, that they have taken the steps necessary to ensure public safety in the event of an accident. Many hazardous materials shippers go beyond the minimum requirements and take additional steps to reduce their liability. They may use a container for hazardous materials that has been tested to more stringent standards than the one that is listed as meeting the minimum standards.
When a hazardous material shipper is ignorant on the DOT regulations or purposely ignores them and continues to ship hazardous materials in a unsafe manner, then the proper agencies have the authority to assess either civil penalties (usually in the form of fines), or criminal penalties. Civil penalties can be assessed for items such as not using the proper shipping name for a hazardous material on a shipping paper or misspelling the name of a hazardous material. Generally, the civil penalties are assessed to those who have accidentally made a mistake in not following the regulations or to those who are ignorant on the regulations and thus have not complied with them.
Criminal penalties are sought when it is determined that a person knowingly and purposefully ignores the regulations and ships a hazardous material illegally. Criminal penalties carry heavy fines and imprisonment for those individuals prosecuted. An example of this might be a person who knowingly ships a hazardous material in a non-UN standard packaging to save money. Both civil and criminal penalties as well as regulatory enforcement are explained in further detail in the 49 CFR, Subpart D.
An example of some common violations and penalties are listed below. The penalties assessed begin with the minimum fine and can be assessed for each incidence or occurrence. For example, if a hazardous material shipper transport ten packages of hazardous materials in non-UN standard packagings, then the fines can be assessed multiplied by ten, one fine for each package that was shipped. The fine for an incident of this nature could be as high as $86,500.
| Violation Description |
Baseline Assessment |
| Failure to label a package, when required |
$4,300 |
| Failure to train hazmat employees in the three area required |
$1,500 to $25,000 |
| Failure to maintain training records |
$500 and up |
Manufacturing, marking, certifying, or selling a package marked to a specification.
UN standard, or an exemption when applicable requirements are not met |
$5,200 to $8,650 |
| Certifying a packaging as meeting a UN standard when design qualification testing was not performed |
$6,000 to $10,800 |
| Offering a hazardous material for transportation in an unauthorized, non-specification, or non-standard packaging |
$5,200 to $8,650 |
| Failure to execute a shipping paper for a shipment of hazardous materials |
$5,200 |
| Failure to include a proper shipping name in the proper § 172.202 shipping description |
$1,850 |
| Failure to include a hazard class/division number in the proper shipping description |
$1,850 |
Section III Terminology
The following definitions are taken right out of the Title 49 Code of Federal Regulations, Parts 100-185. The may not all be used in the text of this guide, however, the language may be used by some hazardous materials shippers and thus is good for future reference and overall general understanding of UN regulations.
Bag means a flexible packaging made of paper, plastic film, textiles, woven material or other similar materials.
Bar means 1 Bar = 100kPa (14.5 psi) (kilopascals in the metric measurement of psi).
Bottle means a container having a neck of relatively smaller cross section than the body and an opening capable of holding closure for retention of the contents. (Example: a tighthead container)
Box means a packaging with complete rectangular or polygonal faces, made of metal, wood, plywood, reconstituted wood, fiber-board, plastic, or other suitable material. Holes appropriate to the size and use of the packaging, for purposes such as ease of handling or opening, or to meet classification requirements, are permitted as long as they do not compromise the integrity of the packaging during transportation, and are not otherwise prohibited in this subchapter.
Cargo aircraft only means an aircraft that is used to transport cargo and is not engaged in carrying passengers. (Example: UPS, Federal Express, Burlington Air Express aircraft)
Carrier means a person engaged in the transportation of passengers of property by: 1) Land or water, as a common contract, or private carrier, or 2) Civil aircraft.
Class means hazard class. See "hazard class".
Closure means a device which closes an opening in a receptacle. (Example: a Rieke flexspout)
Combination packaging means a combination of packaging, for transport purposes, consisting of one or more inner packagings secured in a non-bulk outer packaging. It does not include a composite packaging.
Composite packaging means a packaging consisting of an outer packaging and an inner receptacle, so constructed that the inner receptacle and the outer packaging form an integral packaging. Once assembled it remains thereafter an integrated single unit; it is filled, stored, shipped and emptied as such.
Crate means an outer packaging with incomplete surfaces.
Division means a subdivision of a hazardous class.
Domestic transportation means transportation between places within the United States other than through a foreign country.
Drum means a flat-ended or convex-ended cylindrical packaging made of metal, fiber-board, plastic, plywood, or other suitable materials (example: 5 gallon open head pails and round tightheads containers), but does not include cylinders, jerricans, wooden barrels or bulk packagings.
EPA means U.S. Environmental Protection Agency.
Gross weight means the weight of a packaging plus the weight of its contents.
Hazard class means the category of hazard assigned to a hazardous material under the definitional criteria of part 173 of 49 CFR and the provisions of the 49 CFR hazardous materials table. A material may meet the defining criteria for more than one hazard class but is assigned to only one hazard class.
Hazardous material means a substance or material, which has been determined by the Secretary of Transportation to be capable of posing an unreasonable risk to health, safety, and property when transported in commerce, and which has been so designated. The term includes hazardous substances, hazardous wastes, marine pollutants, and elevated temperature materials as defined in this section, materials designated as hazardous under the provisions of the hazardous material table, and materials that meet the defining criteria for hazard classes and divisions in part 173 of 49 CFR.
Hazmat employee means a person who is employed by a hazmat employer and who in the course of employment directly affects hazardous materials transportation safety....This term includes an individual, including a self-employed individual, employed by a hazmat employer who, during the course of employment:...manufactures, tests, reconditions, repairs, modifies, marks, or otherwise represents containers, drums, or packagings as qualified for use in the transportation of hazardous materials...
Hazmat employer means a person who uses one or more of its employees in connection with: ...representing, marking, certifying, selling, offering, manufacturing, reconditioning, testing, repairing, or modifying containers, drums, or packaging as qualified for use in the transportation of hazardous materials.
Hermetically sealed means closed by fusion, gasketing, crimping, or equivalent means so that no gas or vapor can enter or escape.
Inner packaging means a packaging for which an outer packaging is required for transport. It does not include the inner receptacle of a composite packaging.
Inner receptacle means a receptacle which requires an outer packaging in order to perform its containment function. The inner receptacle may be an inner packaging of a combination packaging or the inner receptacle of a composite packaging.
International transportation means transportation: 1) Between any place in the United States and any place in a foreign country; 2) Between places in the United States through a foreign country; or 3) Between places in one or more foreign countries through the United States.
Jerrican means a metal or plastic packaging of rectangular or polygonal cross-section.
Lading means cargo, load, or contents.
Marking means applying the descriptive name, instructions, cautions, weight, or specification marks or combination thereof required by this subchapter to be placed upon outside containers of hazardous materials.
Maximum capacity means the maximum inner volume of receptacles or packagings.
Maximum net mass means the maximum allowable net mass of contents in a single packaging, or the maximum combined mass of inner packagings, and the contents thereof.
Mixture means a material composed of more than one chemical compound or element.
Mode means any of the following transportation methods; rail, highway, air, or water.
Name of contents means the proper shipping name as specified in 49 CFR hazardous materials table.
Non-bulk packaging means a packaging which has: (1) A maximum capacity of 450L (119 gallons) or less as a receptacle for a liquid. (2) A maximum net mass of 400 kg (882 pounds) or less and a maximum capacity of 450 L (119 gallons) or less as a receptacle for solid;...
Outage or ullage means the amount by which a packaging falls short of being liquid full, usually expressed in percent of volume.
Outer Packaging means the outermost enclosure of a composite or combination packaging together with any absorbent materials, cushioning and any other components necessary to contain and protect inner receptacles or inner packagings.
Overpack,... means an enclosure that is used by a single consignor to provide protection or convenience in handling of a package or to consolidate two or more packages. Overpack does not include a transport vehicle, freight container, or aircraft unit load device. Examples of overpacks are one or more packages: (1) Placed or stacked onto a load board such as a pallet and secured by strapping, shrink wrapping, stretch wrapping, or other suitable means; or (2) Placed in a protective outer packaging such as a box or crate.
Package or Outside Package means a packaging plus its contents...
Packaging means a receptacle and any other components or materials necessary for the receptacle to perform its containment function in conformance with the minimum packing requirements of 49 CFR.
Packing Group means a grouping according to degree of danger presented by hazardous materials. Packing Group I indicates great danger; Packing Group II, medium danger, Packing Group III, minor danger.
Performance-Oriented Packaging (POP) means that the specifications for the design of a packaging is left up to the manufacturer and that only certain minimal performance standards must be met for certification.
Primary Hazard means the hazard class of a material as assigned in the 49 CFR hazardous materials table.
Proper shipping name means the name of the hazardous material shown in Roman print in the 49 CFR hazardous materials table.
RSPA means the Research and Special Programs Administration, U.S. Department of Transportation, Washington, DC 20590.
Siftproof packaging means a packaging impermeable to dry contents, including fine solid material produced during transportation.
Single packaging means a non-bulk packaging other than a combination packaging.
Specific Gravity is the weight of a substance compared with an equal volume of water (water has a specific gravity of 1.0 gram per cubic centimeter).
Solid means a material which is not a gas or liquid.
Solution means any homogenous liquid mixture of two or more chemical compounds or elements that will not undergo any segregation under conditions normal to transportation.
Stowage means the act of placing hazardous materials on board a vessel.
Subsidiary Hazard means a hazard of a material other than a primary hazard.
Technical name means a recognized chemical name or microbiological name currently used in scientific and technical handbooks, journals, and texts....
UN means United Nations.
UN standard packaging means a packaging conforming to standards in the UN recommendations on the Transport of Dangerous Goods.
Vapor Pressure is the pressure exerted by escaping vapor against the internal surfaces of a liquid packaging. The pressure is temperature dependent; as the temperature increases, so does the vapor pressure (i.e., the more of the liquid evaporates or vaporizes). The lower the boiling point of the liquid, the greater the vapor pressure it will exert at a given temperature.
Vessel includes every description of watercraft, used or capable of being used as a means of transportation on the water.
Volatility refers to the relative rate of evaporation of materials to assume the vapor state.
Metric and U.S. standard conversion Table
| Measurement |
Metric to U.S. Standard |
U.S. Standard to Metric |
| Length |
1 cm = 0.3937008 inches
1 m = 3.280840 feet |
1 inch = 2.54 cm
1 foot = 0.3048 m |
| Thickness |
1 mm = 0.03937008 inches |
1 inch = 25.4 mm |
| Mass (weight) |
1 kg = 2.204622 lbs.
1 gr = 0.03527397 oz. |
1 lb = 0.4535924 kg
1 oz = 28.34952 gr |
| Pressure |
1 kPa = 0.1450377 psi
1 Bar = 100 kPa = 14.504 psi |
1 psi = 6.894757 kPa
1 psi = 0.06895 Bar |
| Volume (liquid) |
1 l = 0.2641720 gal
1 ml = 0.03381402 oz
1 m3 = 35.31466 ft3 |
1 gal = 3.785412 l
1 oz = 29.57353 ml
1 ft3 = 0.02831685 m3 |
| Density |
1 kg/m3 = 0.06242797 lb/ft3 |
1 lb/ft3 = 16.01846 kg/m3 |
Section IV Hazardous Materials Packing Groups
Hazardous materials come in many different forms and types such as liquids, solids, gases, radioactive material, etc... In order to easily identify the nature of these hazardous materials, the DOT has assigned classes and divisions for different hazardous materials. There are currently nine different classes listed with some classes containing divisions. The classes are defined by the hazard present based upon the material make-up. For example, Class I represents explosive material and is divided up into six different divisions with each division consisting of material meeting certain criteria which defines the makeup of that division.
For the purposes of using non-bulk plastic containers, there are only six classes, some with divisions, that will apply.
- Class 3 Flammable or Combustible Liquid
- Class 4.1 Flammable Solid
- Class 4.2 Spontaneously Combustible
- Class 4.3 Dangerous When Wet
- Class 5.1 Oxidizer
- Class 5.2 Organic Peroxide
- Class 6.1 Poison
- Class 6.2 Infectious Substance
- Class 8 Corrosive
- Class 9 Miscellaneous hazardous materials
Hazardous materials are often assigned Packing Groups (PG), which indicate the relative degree of danger that a hazardous material presents. These Packing Groups are classified into three categories.
|
Danger Present |
Package Markings |
Container Packaging |
|
|
|
|
| Packing Group I |
Great Danger |
X |
None Available |
| Packing Group II |
Medium Danger |
Y |
Open & Tight Head |
| Packing Group III |
Minor Danger |
Z |
Open & Tight Head |
The assignment of a Packing Group to a hazardous material primarily defines the minimum performance standards that a packaging must meet. For example: a hazardous material given a designation of Packing Group I must have a packaging that can withstand more stringent test requirements than a Packing Group II packaging.
The assignment of a Packing Group is one of the most important elements to determine when selecting the right type of packaging for a hazardous material. Where can the information be found as to the assignment of a Packing Group of a hazardous material? In the Title 49 Code of Federal Regulations hazardous materials table § 172.101.
Section V Hazardous Materials Table
Title 49 Code of Federal Regulations, Parts 100 to 185, contains over 1,200 pages of information regarding the transportation and handling of hazardous materials. Included in the book is the Hazardous Materials Table § 172.101 which contains thousands of entries of various hazardous materials and information regarding packaging, special provisions, quantity limitations and other pertinent details. A manufacturer and shipper of a hazardous material can obtain the necessary information from the table to help determine the type of packaging required and any shipping limitations. A summary of the table is shown below, excluding column 10 which deals with vessel storage requirements. It illustrates an example of Sodium Hypochlorite, 5.25% by weight or commonly known as household bleach.
| |
(8)
Packaging Authorization
(173.***) |
(9)
Quantity
Limitations |
Sym-
bols |
Hazardous materials description and proper shipping names |
Hazard
class or
division |
Identi-
fication
numbers |
PG |
Label
Codes |
Special
Provisions |
Excep-
tions |
Non-bulk
packaging |
Bulk
packaging |
Passenger
aircraft or
railcar |
Cargo
aircraft
only |
| (1) |
(2) |
(3) |
(4) |
(5) |
(6) |
(7) |
(8A) |
(8B) |
(8C) |
(9A) |
(9B) |
| |
|
|
|
|
|
|
|
|
|
|
|
| |
Hypochlorite solutions with more than 5 percent but less than 16 percent available chlorine |
8 |
UN1791 |
III |
8 |
B104,N34
T7 |
154 |
203 |
241 |
5 L....... |
60 L........ |
| |
|
|
|
|
|
|
|
|
|
|
|
| |
Hypochlorite solutions with 16 percent or more available chlorine |
8 |
UN1791 |
II |
8 |
A7,B2
B15, N34
T7 |
154 |
202 |
242 |
I L....... |
30 L........ |
Column (1) Symbols. This column could contain one of five different symbols "+", "A", ":D", "I", and "W". Each of these symbols represents the identification of a proper fixed shipping name, restrictions regarding aircraft usage and vessels and other items. For a complete definition of these symbols, reference Subpart B, section 172.101 of the 49 CFR. For the purposes of the example, there are no symbols affixed to Hypochlorite solutions.
Column (2) Hazardous materials description and proper shipping names. This column contains the hazardous material description and proper shipping names of materials designated as being hazardous.
Column (3) Hazard class or Division. This column contains a designation of the hazard class or division corresponding to each proper shipping name, or the word forbidden. If forbidden appears in this column, then the material may not be offered for transportation.
Column (4) Identification Number. This column lists the identification number assigned to each proper shipping name. Those numbers preceded by the letters "UN" are associated with proper shipping names considered appropriate for international transportation as well as domestic.
Column (5) Packing Group. This column specifies one or more packing groups assigned to a material corresponding to the proper shipping name and hazard class for the material. If more than one packing group is indicated for an entry, the packing group for the hazardous material is determined using the criteria for assignment of packing groups specified in subpart D of part 173 of the 49 CFR.
Note: This is an area which can be complex and somewhat confusing. If the hazardous material intended for packaging does list more than one packing group, either reference 49 CFR, subpart D of part 173 or contact RSPA for further clarification of the Packing Group assignment.
Column (6) Labels. This column specifies codes which represent the hazard warning labels required for a package filled with a material conforming to the associated hazard class and proper shipping name, unless the package is otherwise excepted from labeling.
Note: Labeling of a hazardous material is a function of the shipper or manufacturer of the hazardous material. It is not the responsibility of the packaging manufacturer to provide proper hazardous material labeling for the packaging.
Column (7) Special Provisions. This column specifies codes for special provisions applicable to hazardous materials. The meaning and requirements of these special provisions can only be found in the 49 CFR. Example: Provision N34 states: Aluminum construction materials are not authorized for any part of a packaging which is normally in contact with the hazardous material.
Column (8A) Packaging Authorization Exceptions. This column specifies the applicable exceptions from part 173 of the 49 CFR. These exceptions can often be verbose but should be scrutinized to obtain any necessary information.
Column (8B) Non-Bulk Packaging. This column specifies the applicable sections for non-bulk packaging requirements. Reference 49 CFR for the instructions regarding the details listed under this section.
Column (8C) Bulk Packaging. This column specifies the applicable sections for bulk packaging requirements.
Column (9A) Quantity Limitations for Passenger Aircraft or Railcar. This column specifies the maximum quantities that may be offered for transportation in one package by passenger aircraft and rail car with certain limitations applied. Reference 49 CFR for all the details pertaining to these limitations.
Column (9B) Quantity Limitations for Cargo Aircraft Only. This column specifies the maximum quantities that may be offered for transportation in one package by cargo aircraft with certain limitations applied. Reference 49 CFR for all the details pertaining to those limitations.
Column (10) Vessel Stowage and other stowage provisions. (Not Shown) This column lists vessel stowage requirements and other stowage provisions. Reference 49 CFR for all details regarding these provisions.
Section VI Packaging Performance Testing
All packaging that have been qualified as UN standard packagings, have passed some rigorous testing procedures as defined in 49 CFR. The test procedures are intended to ensure that packages containing hazardous materials can withstand normal conditions of transportation and are considered to be the minimum requirements.
There are five main tests that each non-bulk packaging is subjected to; these are the drop test, the leakproofness test, the hydrostatic test, the stacking test, and the vibration test. Each of these five tests has specific guidelines set up to ensure that the packaging being tested will conform to the respective packing group requirement. A brief overview of each test for packaging is contained below. To find the specific test requirements, reference Subpart M of the 49 CFR.
Drop Test:
A. General. The drop test must be conducted for the qualification of all packaging design types and performed periodically as specified in § 178.601(e). For other than flat drops, the center of gravity of the test packaging must be vertically over the point of impact. Where more than one orientation is possible for a given drop test, the orientation most likely to result in failure of the packaging must be used.
B. Exceptions. For testing of single or composite packagings constructed of stainless steel, nickel, or monel at periodic intervals only (i.e., other than design qualification testing), the drop test may be conducted with two samples, one sample each for the two drop orientations. These samples may have been previously used for the hydrostatic pressure of stacking test. Exceptions for the number of steel and aluminum packaging samples used for conducting the drop test are subject to the approval of the Associate Administrator for Hazardoud Materials Safety.
C. Special preparation of test samples for the drop test. Testing of plastic drums, plastic jerricans, plastic boxes other than expanded polystyrene boxes, compolsite packagings (plastic material), and combination packagings with plastic inner packagings other than plastic bags intended to contain solids or articles must be carried out when temperature of the test sample and its contents has been reduced to ^18° C (0° F) or lower. Test liquids shall be kept in the liquid state, if necessary, by the addition of anti-freeze. Test samples prepared in this way are not required to be conditioned in accordance with § 178.602(d).
For solids and liquids when the test is performed with the hazardous material to be transported or with a non-hazardous material having essentially the same physical characteristic, the drop height is determined according to packing group as follows:
|
Packing Group I |
|
1.8 m (5.9 feet) |
|
|
Packing Group II |
|
1.2 m (3.9 feet) |
|
|
Packing Group III |
|
0.8 m (2.6 feet) |
|
For liquids, if the test is performed with water where the materials to be carried have a specific gravity not exceeding 1.2, the drop height is determined according to packing group as follows:
|
Packing Group I |
|
1.8 m (5.9 feet) |
|
|
Packing Group II |
|
1.2 m (3.9 feet) |
|
|
Packing Group III |
|
0.8 m (2.6 feet) |
|
For liquids, if the test is performed with water where the materials to be carried have a specific gravity exceeding 1.2, the drop height must be calculated on the basis of the specific gravity of the materials to be carried, rounded up to the first decimal, as follows:
|
Packing Group I |
|
SG x 1.5 m (4.9 feet |
|
|
Packing Group II |
|
SG x 1.0 m (3.3 feet) |
|
|
Packing Group III |
|
SG x 0.67 m (2.2 feet) |
| |
Leakproofness Test: The leakproofness test is performed using compressed air or suitable gases on all packaging intended to contain liquids. The design qualification test procedure involves submerging a container with a closure under water while an internal pressure is applied. The test is conducted for a minimum of five minutes with the following pressures applied per packing group.
|
Packing Group I |
|
Not less than 30 kPa (4 psi) |
|
|
Packing Group II |
|
Not less than 20 kPa (3 psi) |
|
|
Packing Group III |
|
Not less than 20 kPa (3 psi) |
|
|
|
|
|
|
| A packaging passes the test if there is no leakage of air from the packaging. |
In addition to the initial qualification test, a production test must be implemented on all containers designed to contain liquids. This production test ensures that all packagings intended for the containment of hazardous material liquids, are free from manufacturing defects such as pin-hole leaks. This test is generally applied with a leak-tester on the production line of the particular packaging. Failure to implement a leak-test during production can result in penalties or fines assessed.
Stacking Test: This test is required for all packagings whether they are designed to contain a solid or a liquid. The test sample is subjected to a force applied to the top surface of the test packaging equivalent to the total weight of identical packages which might be stacked on it during transport. The minimum height of the stack, including the test sample, must be 3.0 m (10 feet). The duration of the test lasts 28 days and is performed at a temperature of not less than 40° C (104° F).
Vibration Test: This test is designed to ensure that each packaging is capable of withstanding, without rupture or leakage, the vibrations that would be typical during transport. The test is performed by placing a filled packaging onto a vibration test platform for the period of one hour. The frequency of the vibration is raised to a level that one could pass a piece of material approximately 1.6 mm between the package and the platform. After one hour, the package is turned on its side and observed for any leakage.
Hydrostatic Pressure Test: This test is required for all packagings intended to contain liquids. The purpose of the test is to ensure that no leakage of liquid occurs due to vapor pressure build-up at various temperatures. Because certain chemicals can emit a vapor that increases as the temperature changes, packagings must be built to withstand the internal pressure that is created. An example of this might be gasoline. As the temperature rises, gasoline vapors expand, thus creating an internal pressure on the container.
The test involves filling the packaging to its prescribed level and applying an internal pressure for at least 30 minutes. The test pressure must be applied continuously and evenly, and it must be kept constant throughout the test period. A hydraulic pressure gauge is connected to the top of the receptacle to record the pressure.
The determination of the hydrostatic pressure rating for packaging selection is dependent upon the interaction between the hazardous materialsâââہ¡¬™ vapor pressure and the temperature.
To determine if a packaging kPa rating meets the needs for a liquid hazardous material, select one of two temperatures to determine the vapor pressure.
Temperature #1.
Method A. The gauge pressure (pressure in the non-bulk container above ambient atmospheric pressure) measured in the non-bulk container at 55° C (131° F) multiplied by a safety factor of 1.5. This pressure must be determined on the basis of the non-bulk container being filled and closed to no more than 98 percent capacity at 15° C (60° F).
Method B. If absolute pressure (vapor pressure of the hazardous materials plus the atmospheric pressure) is used. Multiply the vapor pressure of the hazardous material at 55° C (131° F) by a safety factor of 1.5 and subtract 100 kPa (14.5 psi). If his method is chosen, the hydrostatic test pressure applied must be at least 100 kPa gauge pressure (14.5 psig).
Temperature #2.
Method C. If absolute pressure (vapor pressure of the hazardous material plus atmospheric pressure) is used, multiply the vapor pressure of the hazardous materials at 50° C (122° F) by a safety factor of 1.75 and subtract 100 kPa (14.5 psi). If this method is chosen, the hydrostatic test pressure applied must be at least 100 kPa gauge pressure (14.5 psig).
Note: Packagings intended to contain hazardous materials of Packing Group I must be tested to a minimum test pressure of 250 kPa (36 psi).
Section VII Packaging Marking Requirements
Once a packaging has been determined that it meets the UN standards, a specific marking must be put into the packaging itself identifying it as a UN standard packaging. Typically the marking is embossed onto the bottom of the drum (pail or tighthead) or jerrican container. However, if the packaging and its contents weigh more than 30 kg (66 pounds), the markings need to appear on the top or on the side of the packaging. The marking itself may be applied in a single line or in multiple lines provided the correct marking sequence is used. Slash marks are used to separate the information into sections that are easily defined.
An example and description of the UN marking is indicated below.
UN 1H1 / Y1.8 / 100 / 98 / USA / MFG #
UN The UN Symbol indicates the packaging is UN approved.
1 This number indicates the kind of packaging.
- "1" means a drum
- "3" means a jerrican
- "6" means a composite packaging
H Capital letter indicates the materials of construction.
- "H" means plastic
- "HH" means plastic composite with inner lining.
- "A" means steel
1 This number indicates the category of packaging within the type to which the packaging belongs.
- "1" indicates a non-removable head - tighthead
- "2" indicates a removable head - openhead
Y This letter identifies the packing group for which the packaging performance was tested.
- "X" for packing group I, II, or III tests.
- "Y" for packing group II or III tests.
- "Z" for packing group III tests.
1.8 This number indicates the specific gravity for which the packaging was tested. For solids, the designation is the maximum gross mass in kilograms. (This marking indicates that it was tested for a 1.8 specific gravity).
100 For packagings intended to contain liquids, the hydrostatic test pressure is listed rounded down to the nearest 10 kPa.
98 The last two digits of the year of manufacture.
USA The letters USA indicate that the packaging is manufactured and marked in the United States.
MFG# This indicates the name and address of the manufacturer as registered with the Associate Administrator for Hazardous Materials Safety.
REMEMBER, just because there is a UN marking, doesn't mean that it can't be used for non-hazardous materials. In fact, some customers prefer it!
Note: The marking of a packaging is the responsibility of the packaging manufacturer and differs greatly from the labeling of a hazardous material which is the responsibility of the hazardous material shipper. Marking of a packaging and labeling or marking of a hazardous material package can be confused as being one in the same, but they are both very different.
Section VIII Hazardous Material Marking & Labeling
Once a UN standard packaging has been selected, the shipper must provide identification of the hazardous material directly on the packaging. This identification comes in the form of marking and labeling.
The many requirements of hazardous material marking and labeling can be found in subparts D & E of the 49 CFR. A shipper of hazardous materials should be quite knowledgeable about the requirements of hazardous material marking and labeling to avoid severe penalties from the mismarking or labeling of a hazardous material. Some of the requirements are listed below but do not reflect all of the requirements or exceptions to hazardous material marking and labeling. Consult the 49 CFR for all requirements before shipping a hazardous material.
- Include the proper hazardous material shipping name and UN identification number if applicable. A "UN" marking should be included preceding the UN identification number or a "NA" marking if the material has not been assigned a UN number.
- Include the technical name in parenthesis in association with the proper shipping name.
- Consignee's or consignor's name and address if required.
- Include the specified label as indicated in column 6 of the 49 CFR hazardous material table. These labels have specific characteristics which have been universally adopted and should always be used with the right hazardous material. These labels have been designed to correspond to the proper hazard class.
Section IX Customer Notification Requirements
It is required by the 49 CFR that any distributor or manufacturer who sells hazardous materials packagings comply with the requirements of all applicable CFR regulations. This includes notifying in writing, each customer to whom a UN packaging is sold, the type and dimensions of any closures, including gaskets as well as procedures for installing closures needed to satisfy performance test requirements. This is a legal responsibility of the manufacturer and of their distributors.
The manufacturer provides copies of the notification information and closure instructions in each test report that is generated for the certification of a UN packaging.
Upon delivery of the closure instructions, if possible, walk the customer through any packaging closure procedures to ensure that they are performing it correctly. Retain copies of each written notification for at least one year from date of issuance; and keep copies on file at your respective facility for inspection by a representative of the Department of Transportation if requested. Remember, in the eyes of the DOT, any company that handles, distributes, or manufactures hazardous materials packagings, is considered a hazardous materials employer and thus must comply with the hazardous materials regulations!
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