Quick Guide: Shipping Hazmat With No Packing Group
US and international authorities removed packing group or "PG" from articles for several reasons. Before the rule change, some articles were assigned packing groups (e.g., wet batteries) and others were not (e.g., aerosols). When articles were assigned a packing group, it did not accurately reflect the degree of danger. Removing PG assignments from these articles made the HMR more consistent.
Articles No Longer Assigned Packing Groups
The January 2015 Final Rule removed PG assignments from the following articles:
| UN2017 | Ammunition, tear-producing, non-explosive, without burster or expelling charge, non-fuzed |
| UN2016 | Ammunition, toxic, non-explosive, without burster or expelling charge, non-fuzed |
| UN3506 | Mercury contained in manufactured articles |
| UN3356 | Oxygen generator, chemical |
| UN3268 | Safety devices, electrically initiated |
| UN1700 | Tear gas candles |
| UN3292 | Batteries, containing sodium |
| UN2794 | Batteries, wet, filled with acid, electric storage |
| UN2795 | Batteries, wet, filled with alkali, electric storage |
| UN2800 | Batteries, wet, non-spillable, electric storage |
| UN3480 | Lithium ion batteries including lithium ion polymer batteries |
| UN3481 | Lithium ion batteries contained in equipment including lithium ion polymer batteries |
| UN3481 | Lithium ion batteries packed with equipment including lithium ion polymer batteries |
| UN3090 | Lithium metal batteries including lithium alloy batteries |
| UN3091 | Lithium metal batteries contained in equipment including lithium alloy batteries |
| UN3091 | Lithium metal batteries packed with equipment including lithium alloy batteries |
What Is a Packing Group (PG)?
The HMR defines packing group to mean "a grouping according to the degree of danger presented by hazardous materials in 49 CFR 171.8. The purpose of packing groups is twofold. First, PG indicates the degree of danger presented by the material compared to others in the same class or division.- PG I indicates great danger
- PG II indicates medium danger
- PG III indicates minor danger
- X-rated packagings are strong enough to hold PG I, PG II, or PG III mateirals.
- Y-rated packagings may be used to ship PG II or PG III materials. Not PG I.
- Z-rated packagings may be used for PG III materials only
What Is a Hazmat Article?
Unfortunately for shippers, the hazmat regulations do not define the term "article." In regulatory and industry circles, a commonly-used definition comes from the OSHA Hazard Communication Standard (HCS), which defines "article" to mean—Some article may contain a regulated hazardous materials. That said, an "article" has more purpose than a container, which is why articles are treated differently."a manufactured item other than a fluid or particle: (i) which is formed to a specific shape or design during manufacture; (ii) which has end use function(s) dependent in whole or in part upon its shape or design during end use; …."
[29 CFR 1910.1200(c)]
For example:
-
A sealed glass ampule holding mercury is a container, not an article. It would be shipped as "UN 2809, Mercury, 8(6.1)" and assigned to Packing Group II
-
Put the same mercury in a long, cylindrical glass ampule, however, and draw some lines on the side to measure temperature, and now you have a thermometer, which is considered an article, and would be shipped as "UN 3506, Mercury Contained in Manufactured Articles, 8(6.1)" and no packing group assignment
What Else Doesn't Get a Packing Group?
Hazmat with no packing group is not a new idea. Gases (Class 2), infectious substances (Division 6.2), and radioactive materials (Class 7) never had packing group assignments. In other cases, like with explosives (1) or organic peroxides (5.2), the "severity of hazard" for a material is communicated in some way other than using PG I, II, or III.Watch the video at the top of the page to learn more about how these "non-PG" hazard classes and divisions are divided up to indicate which materials are more hazardous than others.
What Does It Mean to Not have a Packing Group?
Without a packing group, you don't automatically know what level of packaging to use for an article like you do for common industrial hazardous chemicals. However, the packing instructions and/or special provisions for articles and other materials without packing groups will always specify the type and strength of packaging to ship the articles.Not having a packing group doesn't mean much by itself. It means that the packing group section on the shipping papers will be left blank, because there's nothing to put there. [49 CFR 172.202(a)(4)] Also, while marking the PG on the package has never been a requirement, if you do mark your packages with their contents' packing group, you risk noncompliance if packing group assignments no longer apply to your particular article or material.
Last Multimodal Hazmat Shipper Workshops of 2016!
The final Complete Multimodal Hazmat Shipper Workshops (49 CFR, IATA, IMDG) of 2016 are starting soon. Get up to speed with the latest rules for hazmat ground, air, and vessel shippers—including new rules for air shipments in the 58th edition IATA Dangerous Goods Regulations—when the workshops come to Kansas City on October 25-28, Detroit on October 31-November 3, Cincinnati on October 31- November 3, Pittsburgh on December 5-8, and Chicago on December 12-15.Sign up now to keep your hazmat shipments in compliance, in 2017 and beyond!
Tags: 49 CFR, DOT hazmat, hazardous materials, hazmat in articles, packing groups
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