Protecting Your Packages from Incidents in Transit
The bottles, cans, jars, and test tubes inside of your combination packaging must remain closed when they are subject to shocks, vibrations, and changes in temperature and pressure during transportation. A box rattling along a bumpy road in the back of a truck, climbing to 35,000 feet in a matter of minutes inside of an airplane’s cargo hold, heating up on a train stopped on the tracks in the desert, or rolling with the waves on a ship may experience extreme conditions that could compromise your inner packagings. The DOT’s general packaging regulations require you to ensure your packages get from point A to point B without a failure.
Follow Packaging Instructions
When using UN specified packaging, you must follow the manufacturer’s written instructions for closing the package and inner packagings. Closures must be leakproof and secured against loosening.
Up in the Air Packages shipped by air are regulated even more stringently than those shipped by ground (49 CFR 173.27(d)). When shipping by air, “inner packaging or receptacle closures of combination packages containing liquids must be held securely, tightly and effectively in place by secondary [i.e., positive] means.” How should you secure stoppers, corks, snap-on devices (i.e., paint can lids), or other friction closures? The Department of Transportation (DOT) provides examples of what you may use, which include adhesive tape, friction sleeves, welding or soldering, locking wires, locking rings, induction heat seals, and child-resistant closures.
Don’t Make Assumptions
The concept of positive closure is not always intuitive. In a letter of interpretation dated October 18, 2011 (PHMSA #11-0165), the DOT addressed whether it considers tamper-evident caps with break-away rings (such as the cap on a 20-ounce bottle of soda or on a gallon of milk) as acceptable. The Agency stated, “…it is the opinion of this Office that the tamper-evident cap you reference does not meet the HMR positive means of closure requirement.” In another letter of interpretation dated May 12, 2004 (PHMSA #04-0011), the DOT addressed placing weight on snap lids to keep them in place and concluded, “downward pressure alone exerted upon a friction-type closure does not satisfy this requirement.”
Stay Compliant and Safe
The bottom line is, “when in doubt, don’t ship it out.” Make sure your inner packagings will still be closed when they get to their final destination because, in addition to subjecting your company to substantial fines for non-compliance, if a package fails, a release of hazardous materials can harm people, property, and the environment—and hurt your company’s reputation.
Be confident your hazmat packages comply with the ground, air, and ocean shipping regulations. At Lion Technology’s Multimodal Hazmat Shipper Certification Workshops, you’ll benefit from engaging, effective training that covers the latest 49 CFR, IATA, and IMDG regulations you must follow to prevent incidents in transit, costly delays, and civil penalties.
Tags: DOT, hazmat shipping
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