Shipping hazardous materials involves compliance with a host of applicable regulations dependent on the material and mode of transport in order to ensure the safety and well-being of all involved in the process. However, confusion over certain aspects of hazmat transport leads to repeated violations of such rules. In order to help keep shippers aware of where they might unknowingly be breaching hazmat shipping regulations, the following is a list of the five most common packaging violations that we have observed during our decades of work in this space:
- Closure Instructions – Failure to Follow Closure Instructions (for example, applying closures consistent with the manufacturer’s closure instructions) and to maintain them in accordance with DOT recordkeeping is one of the most frequently cited violations assessed by DOT. The Hazardous Materials Regulations (HMR) require shippers to maintain a copy of the manufacturer’s notification, including closure instructions (see §178.2(c) of the HMR), unless permanently embossed or printed on the packaging. The packaging closure instructions and supporting documentation must be made available for inspection by a DOT representative upon request for the time period of the packaging’s periodic retest date, which is every 12 months for single or composite packagings and every 24 months for combination packagings.
- Necessary Compliance Functions – Failure to perform all functions necessary to bring the package into compliance with the HMR, as identified by the packaging manufacturer or subsequent distributor, is another common violation. Most packagings are tested and certified for specific use. Some shippers do not understand this concept and think they simply need to pack their materials in any 4G box or 1A1 drum, which can have drastic consequences. In addition, shippers need to make certain the hazardous material is compatible with every piece of the packaging. We often see materials in packaging that will react with secondary packaging (especially foam) or even in primary packaging (corrosives in unlined metal inners). To ensure compliance, it is imperative to review the manufacturer’s documentation, including the packaging test report. If the manufacturer or distributor is unable to provide the appropriate documentation and technical support, then it is best to find one than can provide the necessary information.
- Special Permits – If a special permit or approval authorizes the use of a packaging by a person other than or in addition to the holder of the special permit or approval, that person may use the packaging for the purposes authorized subject to the terms specified. If you are using or considering using a packaging subject to a special permit or approval, ensure that you understand the terms and conditions and that you are authorized to use the special permit or approval. Employees with responsibilities for using these packagings must receive function-specific training consistent with the terms and conditions. Copies of special permits and approvals may be obtained by accessing the Hazardous Materials Safety Web site.
- Air and Sea Shipping – If you are shipping by air or sea, ensure that you are familiar with the applicable packing instructions in the ICAO Technical Instructions and IMDG Code. When shipping by air, the applicable packagings and quantity limits are much more conservative as compared to those that can be used for ground shipments. Additionally packagings offered for air transport must meet additional performance requirements (e.g. pressure differential). Be sure to review the applicable requirements, particularly those in §173.27 of the HMR.
- Packaging Reuse – It is important to understand the limitations for reusing packagings. Packagings and receptacles, including closure devices and cushioning materials, used more than once must be in such a condition that they conform in all respects to the prescribed requirements of the HMR. Before reuse, each packaging must be inspected and may not be reused unless it is free from incompatible residue or damage which reduces its structural integrity. Packagings which have significant defects that cannot be repaired may not be reused. Reused Division 6.2 packaging must be disinfected prior to reuse by any means effective for neutralizing the infectious substance the packaging previously contained.
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At Labelmaster, we take the steps necessary to help ensure your packaging is in compliance with all applicable regulatory requirements. All Labelmaster UN packaging includes closure instructions either printed on the box or as papers shipped with the kits as well as requisite packaging test reports. Starting later this year, we’ll also be including PDF copies of closure instructions on our Web site.
Hazmat shippers should also take note of the variety of services and solutions we offer:
- Have a question about whether you can use a special permit, reuse a packaging, or if you’re in compliance with air or sea hazmat shipping regulations? Give our regulations department a call at 800-621-5808 and we’ll be happy to answer your inquiry.
- Our hazmat shipping consulting team can provide a comprehensive analysis of your shipping program. Evaluations include a confidential report of all logistic program strengths and deficiencies noted with specific instances detailed for consideration or correction.
- If you prefer to leave your company’s hazmat shipping to the experts, our packing services group provides a safe, secure and reliable service for shipping hazardous cargo domestically and internationally.