Size Matters: Shipping Hazmat in Big Boxes

Posted on 6/20/2016 by Roger Marks

“Good things come in small packages,” the saying goes. But sometimes, a small package or combination packaging just won’t get the job done. Luckily, the US and international hazmat shipping rules recognize that, sometimes, good things come in very big packages, too. In both 49 CFR and the IMDG Code, shippers can find specific requirements and guidance for shipping large packages. Below is a Q&A on using large packagings, like the Gaylord boxes pictured below, to ship hazardous materials by ground and vessel.

Shipping 1,000 Cans of Paint Thinner

The Problem: I need to ship 1,000 cans of flammable paint thinner to Haiti, by vessel, using the IMDG Code. The paint thinner is pre-packaged in 5-liter metal cans. The cans are suitable as inner packagings only, so I can’t ship them by themselves. The 1,000 cans weigh more than 5,000 kg net weight.

Q: Is there any way to ship them all in one box?

A: Yes, there is a way to ship them all in one box. The non-bulk hazmat packaging instruction in the IMDG Code (P001; 4.1.4) limits the net quantity per package to 400 kg. So, to use instruction P001 to ship 1,000 cans of paint thinner, we would need more than ten outer packagings of 400 kg or less each. To ship all of the cans in the same package, we’re going to need a bigger box. This is where Large Packgings come into play.

Q: What’s Considered a Large Hazmat Package?

A: 49 CFR 171.8 and IMDG 1.2 define large packaging as a “packaging which contains articles or inner packagings which are designed for mechanical handling and exceed 400 kg net mass or 450 liter capacity but have a volume of not more than 3 cubic meters.” You can think of a large packaging as a bulk-sized combination packaging. The dangerous goods are inside many small individual inner packagings, which are themselves aggregated together inside one capacious outer packaging. Large packagings are constructed to UN specifications and commonly constructed of rigid fiberboard, but they can also be constructed of metal, wood, or plastic.

Large hazmat packagings or gaylord boxes

Q: Do I need to follow general packaging requirements?

A: Yes. Large packagings have the same general packaging requirements as smaller packages (IMDG, 49 CFR 173, Subpart A). Like all hazmat packaging, large packagings must be in good condition, meaning without damage like holes, tears, or material degradation like softening from water damage. Employees must follow the manufacturer’s assembly and closure instructions when putting together and closing the package—assembling the package as directed and using the inner receptacles described in the instructions. Packagers should ensure the inner packagings are properly cushioned to withstand the rigors of transportation, such as rough roads and rough seas.

When assembling and closing any hazmat package, especially a large one, use only the methods and materials that are described by the instruction. As with all hazmat shipments, the materials you ship must be compatible with the packagings. This means that the material cannot react dangerously with the packaging (e.g., soften plastic or destroy metal or glass). Lastly, for liquids, proper space must be provided for expansion of the contents in the package. Specifically, inner packagings must not be completely liquid full at 130°F (55°C). [IMDG]

Q: Do large hazmat packagings need to be authorized for UN specification packagings?

A: Yes. In addition to meeting the same general packing requirements as smaller packagings, large packagings must:

• Be authorized by applicable packing instructions at 49 CFR 173 and IMDG 4.1.4, and
• Meet UN specifications at 49 CFR 178 or IMDG Part 6.

Q: How do I know if large packagings are authorized for my material?

A: For ground shipments, hazmat may be packed in large packagings if the special provisions and packing instructions cited in the Hazmat Table at 49 CFR 172.101 authorize their use. The appropriate special provisions are listed at 49 CFR 172.102 under the IB and IP codes, usually associated with intermediate bulk containers (IBCs).

The packing instructions for large packagings are part of the instructions for bulk packagings at 49 CFR 173.240, et seq. For vessel shipments, if the packing instruction in Column 8 of the 3.2 Dangerous Goods List of the IMDG Code includes an option with an LP code (e.g., LP01), then large packagings are authorized for that material.

Q: How do I use the instructions for large packagings?

A: Column 1 of the instruction lists authorized inner receptacles (e.g., glass). Column 1 also indicates the maximum quantity per inner receptacle (e.g., 10 L). Column 2 indicates the type(s) of outer packages (e.g., rigid fiberboard) that are authorized and the corresponding UN specification code (e.g., 50G).

Columns 3 to 6 indicate the maximum net quantity of hazmat in the large packaging based on packing group (e.g., 3 m3). The packaging instruction may also direct shippers to use intermediate packaging materials, such as dividers or absorbent material. Special packaging provision codes (e.g., L2) in Column 9 of the dangerous goods list must be followed if applicable.

Q: What about special provisions? Do they apply to large packagings?

A: Yes. For ground shipments, any special provisions indicated in Column7 of the 172.101 Hazmat Table will apply. For vessel shipments, all special provisions listed in Column 6 of the 3.2 Dangerous Goods List (e.g., 163, 223) must be checked in the special provisions section at IMDG 3.3 for applicability to your material and shipment.

Trusted 49 CFR, IATA, and IMDG Hazmat Training

If you ship hazmat by ground, air, or vessel, staying up to speed with the latest requirements is crucial. If you miss changes to the rules or you don’t fully understand the requirements, hazmat inspectors can levy fines up to $75,000 per day, per violation. Be confident you know the details about how complex  regulations affect your shipments, and leave nothing to chance. At the Complete Multimodal Hazmat Shipper Workshops, you’ll learn to choose the hazmat package that best meets your needs and keeps your shipment in compliance.

Build a step-by-step approach to classifying materials; choosing hazmat Proper Shipping Names; packaging, marking, and labeling DG shipments; filling out proper documentation;  meeting your reporting and recordkeeping responsibilities; and much, much more.  Don’t miss the workshops in  July, when the hazmat training trusted nationwide comes to New Jersey, Boston, Baltimore, Hartford, Philadelphia, Williamsburg, and Charlotte.

Tags: DOT, hazmat shipping, PHMSA

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