Transportation
Volume 8, Issue 41
Feature ArticleMix and Match? Combination Packages Dos and Don'ts As you're preparing a hazmat shipment, if you ever find yourself saying, “I think I'll just grab these plastic bottles and pack them up in a UN certified box stored in the back closet,” STOP! Random mixing and matching of packaging components is not allowed. There are two important concerns at work here. First, you must choose packaging that is specifically authorized by the DOT in column 8 of the 49 CFR 172.101 hazardous materials table and take into account any applicable special provisions listed in column 7 of the table for your material. Secondly, once you choose authorized packaging, you must strictly adhere to the packaging manufacturer’s instructions for properly preparing your package. Packaging manufacturers administer performance tests on the whole “kit and caboodle” for combination packages. When they certify that the packaging meets all the required specifications they are saying this is true only “as is.” In other words, you can’t just swap pieces, and you can’t leave anything out either. For example, if a combination packaging was tested with 1-liter cylindrical metal inner receptacles and certified using a fiberboard, 6-section divider, you must use the same divider and inner packagings when you prepare your package for transport. The manufacturer is required to provide users of their product with a written notification of how to assemble, fill, and close the package, so that you will be duplicating their certification conditions [see 49 CFR 178.2(c)]. These testing procedures are intended to ensure that packages containing hazmat can withstand the rigors of normal transportation. Any unauthorized variation can mean non-compliance—and possible package failure. Some variations are permitted but require you to meet very specific standards. If you want to use different inner packagings without further testing, they must provide an equivalent level of performance by being: • The same or smaller size, In addition, you’d have to use sufficient additional cushioning material to take up any voided space, orient the inner packagings the same way, and stay under the original gross mass limits. You may pack fewer inner packagings than used for the original tests, provided you cushion adequately. Inner packagings that have been tested may be used without retesting an outer packaging only if the outer packaging was successfully tested with fragile inner packagings containing liquids at the Packing Group I drop height (5.9 feet) AND the total combined gross mass of inner packagings does not exceed one-half the gross mass used for the drop test. For the regulations pertaining to allowed variations see 49 CFR 178.601(g). Or, make your life easy by purchasing a tested and certified kit from a packaging manufacturer. Then remember to precisely follow their instructions—right down to what kind of tape to use to close the box. And when you’re done, there better not be any extra pieces left over!
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DOT & International Transportation News 10/01/2007—$250,000 Grant Boosts Hazardous Materials Response Training Around the Nation 10/01/2007—DOT Grants $372,000 to American Indian Tribes to Improve Hazardous Materials Planning and Training 10/01/2007—DOT Grants $12.8 Million to First Responders and Emergency Workers to
Improve Hazardous Materials Planning and Training U.S. Transportation Secretary Mary E. Peters today announced grants to states, territories and Native American tribes totaling $12.8 million for planning and training to improve the nation’s response to hazardous materials transportation incidents. The grants help train first responders to react to incidents involving hazardous materials and to meet the challenges posed by new chemicals and alternative energy products like ethanol. 09/28/2007—Pipeline and Hazardous Materials Safety Administration Opens Comment Period for Revised Edition of “How to Use the Hazardous Materials Regulations” The popular guidebook “How to Use the Hazardous Materials Regulations” is being considered for revision in 2008.
View more DOT news View more International news Recent DOT Rules, Standards, and InterpretationsFor Lion Members and Recent Course Attendees 10/01/2007—Hazardous Materials Regulations: Minor Editorial Corrections and Clarifications 10/01/2007—Technical Amendments to Federal Motor Carrier Safety Regulations 09/28/2007—Hazardous Materials: Revision and Reformatting of Requirements for the Authorization To Use International Transport Standards and Regulations; Correction 09/28/2007—Hazardous Materials Regulations: Transportation of Compressed Oxygen, Other Oxidizing Gases and Chemical Oxygen Generators on Aircraft 09/28/2007—Transportation Worker Identification Credential (TWIC) Implementation in the Maritime Sector; Hazardous Materials Endorsement for a Commercial Driver's License
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