© Jan 2013 Jerry Green Consulting, Inc. www.haztraining.com
Packaging of Hazardous Materials
And Dangerous Goods for TransportA Packaging Vocabulary
The following terms are used throughout the packaging regulations. These definitions are based on 49CFR §171.8
Packaging means a receptacle and any other components or materials necessary for the receptacle to perform its containment function in conformance with the minimum packaging requirements.
Package means a packaging plus its contents.
Bulk packaging means a packaging in which hazardous materials are loaded with no intermediate form of containment and have:
A maximum capacity greater than 450 L (119 gallons) as a receptacle for a liquid;
A maximum net mass greater than 400 kg (882 pounds) and a maximum capacity greater than 450 L (119 gallons) as a receptacle for a solid; or A water capacity greater than 454 kg (1000 pounds) as a receptacle for a
Non bulk packaging means a packaging which has:
A maximum capacity of 450 L (119 gallons) or less as a receptacle for a liquid;
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 a solid; or
A water capacity of 454 kg (1000 pounds) or less as a receptacle for a gas. Non bulk packaging vocabulary includes:
Combination packaging means a combination of packaging, for transport
purposes, consisting of one or more inner packagings secured in a non-bulk outer packaging.
Single packaging means a non-bulk packaging other than a combination packaging (a single packaging contains no inners).
© Jan 2013 Jerry Green Consulting, Inc. www.haztraining.com 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. Examples of overpacks are one or more packages:
Placed or stacked onto a load board such as a pallet and secured by strapping, shrink wrapping, stretch wrapping, or other suitable means or Placed in a protective outer packaging such as a box or crate.
General Requirements for Packages and Packagings
This section applies to all hazard classes and all configurations, large or small. It applies to bulk and non-bulk packaging. The section serves to create a minimum standard for all levels of packaging.
The principal minimum standard is that the packaging must not leak its contents under conditions that are normally incident to transport.
Additional minimum standards address: Compatibility
Ullage/filling limits for liquids
Prohibitions concerning compromised packagings Mixed contents
© Jan 2013 Jerry Green Consulting, Inc. www.haztraining.com The Rule of Packaging
UN Performance Oriented Packagings
Packaging requirements vary with the level of risk associated with the materials, however the rule of packaging for most materials is fairly simple; a specification packaging must be used. Of course, many exceptions exist to this rule.
Today's modem specification system for many dangerous goods and hazardous materials is a UN Performance Oriented Packaging System. UN packagings go through a series of tests designed to emulate what can happen to a package during routine transport. Drop tests, stack tests, and other testing protocols are performed.
UN packagings bear a unique certification marking which is pictured below:
The UN employs a series of numbers and letters (4G) to identify the system. In this example, the 4 means the packaging is a box, and the G means it is constructed of fiberboard.
1A1 Steel drum, non-removable head
1A2 Steel drum, removable head
1B1 Aluminum drum, non-removable head
1B2 Aluminum drum, removable head 1D Plywood drum
1G Fibre Drum
1H1 Plastic drum, non-removable head
1H2 Plastic drum, removable head
1N1 Metal Drum, non-removable head 1N2 Metal Drum, removable head 2C1 Wooden barrel, bung type
2C2 Wooden barrel, removable head
3A1 Steel jerrican, non-removable head
3A2 Steel jerrican, removable head
3H1 Plastic jerrican, non- removable head
3H2 Plastic jerrican, removable head
4A Steel box
4B Aluminum box
4C1 Wooden box, ordinary
4C2 Wooden box with sift-proof walls
4D Plywood Box
4F Reconstitued wood box
© Jan 2013 Jerry Green Consulting, Inc. www.haztraining.com Packaging Selection —
HMR The Process
Step 1: Once you have determined the correct proper shipping name you must consult Column 7 of the HMT. Please remember that many special provisions are written which can affect your ability to package material. Of particular note are "N" codes which address non bulk packaging. For example, special provision N33 prohibits the use of aluminum drums.
Step 2: If you have addressed the issues concerning Column 7, you must consult Column 8 of the HMT. Please remember the role of the three sub columns. Packaging exceptions are listed in Column 8A and non-bulk packaging selection is the role of Column 8B. Step 3: You must always comply with the General Requirements for Packages and Packagings in §173.24. Remember that compatibility and other issues reside here. Step 4: If using a UN specification packaging, you must verify that the packaging is eligible for the material to be placed inside. For example, a PG I material can only be placed in a system marked with an "X". Remember that combination packages and single packagings for solids have maximum weight limits
.UN Packaging Assembly, Filling, and Closure Requirements
Please remember that most UN packagings are tested systems, meaning that all components, including inners have been tested when assembled and filled with material which closely resembles hazardous material. Generally, the user is not permitted to depart from the assembly and closure requirements.
Variation Packaging — The V System
Articles or inner packagings of any type for liquids and solids can be assembled without testing under certain conditions in Part 178 of the HMR. Known as a variation
packaging, the system will bear a "V" marking after the marked packaging code, such as "4GV". This is an excellent method of packaging materials when it is impossible to comply with the requirements of a tested system. Please consult §178.601(g)(2).