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Unless specifically indicated otherwise, a person must follow certain guidelines to offer a hazardous material for transportation in a package or container. The person who offers the hazardous material is required to classify and describe the hazardous material in accordance with the Hazardous Materials Regulations and to determine that the packaging or container is an authorized packaging. The packaging must also have been manufactured, assembled, and marked in accordance with specific sections of the regulations.
The Hazardous Materials Regulations (HMR) are issued by the U.S. Department of Transportation (USDOT) and govern the transportation of hazardous materials in interstate, intrastate, and foreign commerce. The primary goal of the HMR is the safety of the public and those whose occupations involve preparing hazardous materials for transportation or transporting them. To minimize risks, USDOT has issued specific requirements for shipments of hazardous materials in transportation. The HMR are divided into four general areas:
A basic understanding of the HMR is required for compliance with the regulations.
Unless specifically indicated otherwise, a person must follow certain guidelines to offer a hazardous material for transportation in a packaging or container required by Part 173 of the Hazardous Materials Regulations (HMR).
The person who offers the hazardous material is required:
What is a packaging?
According to the definition in Section 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 packing requirements of the HMR.
The following marks may be used to determine whether or not the packaging is authorized:
DOT specification or UN standard packagings
A person who offers a DOT specification or UN standard packaging that is subject to the requirements in Part 178 of the HMR is required to perform all functions necessary to bring that package into compliance with Parts 173 and178 of the HMR, as identified by the packaging manufacturer or subsequent distributor, in accordance with Section 178.2 of the HMR.
Shipments of fissile radioactive materials, and Type B or highway route controlled quantity packages of radioactive materials
The shipper is required to notify the consignee of the dates of shipment and expected arrival. The shipper must also notify each consignee of any special loading/unloading instructions prior to the first shipment.
Shipments of irradiated reactor fuel
The shipper must provide physical protection in compliance with a plan established under either:
Notes: The shipper’s certification on a shipping paper for transportation of hazardous materials requires the shipper to certify that the above-named materials are properly classified, described, packaged, marked and labeled, and are in proper condition for transportation according to the applicable regulations of the DOT.
The shipper, or the person or employee of the person who originates the shipment for transportation is responsible for properly preparing the hazardous material for transportation. The hazardous material must be properly classified to ensure that it is prepared using the proper packaging, marking(s), and label(s). If a company is a shipper of hazardous material, it is responsible to understand the preparation requirements including all applicable packaging related requirements.
Hazardous materials can only be transported in packaging that are authorized by the Hazardous Materials Regulations (HMR). The packaging authorized in Part 173 can only be used for a hazardous material if the section in Part 173 is referenced in Column 8 of the Hazardous Materials Table for the proper shipping name chosen for the material.
Part 173 provides detailed packaging rules for each class of hazardous materials. The packaging requirements set for a specific hazardous material are the same for all modes of transportation unless otherwise stated or exceptions are authorized.
Specification packaging are cylinders, portable tanks, cargo tanks, and tank car tanks for which the Department of Transportation (DOT) has issued detailed manufacturing specifications.
Manufacturers must mark all authorized packagings as required by Parts 178 and 179 of the Hazardous Materials Regulations (HMR). This marking is the manufacturer’s certification that the packaging has been manufactured and tested in accordance with Parts 178 and 179.
At periodic intervals and whenever a company needs to qualify a package design, it must perform drop tests from distances between 2.2 feet and 5.9 feet, as specified in 178.601(e) and 178.603. For other than flat drops, the center of gravity of the test packaging must be vertically over the point of impact.
To periodically test single or composite packagings constructed of stainless steel, nickel, or money, the drop test may be conducted with two samples—one sample each for the two drop orientations. The regulations allow companies to use samples that may have previously been used for the hydrostatic pressure or stacking test.
For details about exceptions for the number of steel and aluminum packaging samples used for conducting the drop test, contact the Pipeline and Hazardous Materials Safety Administration (PHMSA).
Passing the test
A package is considered to successfully pass the drop tests if, for each sample tested:
Using compressed air or other suitable gases, a company must perform a leakproofness test on all packagings intended to contain liquids. The packaging must pass the test — i.e., no air leaks from the packaging — before being used in transportation and before any reuse authorized under 173.28. Normally, three samples of each different packaging must be tested.
For design qualification and periodic testing, packagings must be tested with closures in place. For production testing, however, this is not necessary, and removable heads need not be installed, either. For testing with closures in place, vented closures must either be replaced by similar non-vented closures, or the vent must be sealed.
In testing, the packaging must be restrained under water while an internal air pressure is applied, and the method of restraint must not affect the results of the test. The test must be conducted, for other than production testing, for a minimum time of five minutes. Other methods, at least equally effective, may be used in accordance with Appendix B of Part 178.
An internal air pressure (gauge) must be applied to the packaging as indicated for the following packing groups:
Passing the test
A packaging passes the leakproofness test if there is no leakage of air from the packaging.
At periodic intervals and whenever qualifying a metal, plastic, and composite packaging design type intended to contain liquids, a company must perform the hydrostatic pressure test as specified in 178.601(e) and 178.605, and no leakage can occur. This test is not required, however, for inner packagings of combination packagings. For internal pressure requirements for inner packagings of combination packagings intended for transportation by aircraft, see 173.27(c).
Normally, the regulations require three test samples for each different packaging — although one will suffice for packagings constructed of stainless steel, monel, or nickel. Other exceptions require approval from the Pipeline and Hazardous Materials Safety Administration (PHMSA).
Replace vented closures with similar non-vented closures or seal the vent during the test.
Metal packagings and composite packagings other than plastic (e.g., glass, porcelain or stoneware), including their closures, must be subjected to the test pressure for five minutes. Plastic packagings and composite packagings (plastic material), including their closures, must be subjected to the test pressure for 30 minutes.
This pressure is the one to be marked as required in 178.503(a)(5) of this part. The receptacles must be supported in a manner that does not invalidate the test. The test pressure — as specified in detail in 178.605(d) — must be applied continuously and evenly, and it must be kept constant throughout the test period.
Passing the test
A packaging passes the hydrostatic test if, for each sample, there is no leakage of liquid from the packaging.
All packaging design types, other than bags, must be subjected to a stacking test. The regulations require three test samples for each different packaging — except for one each for periodic retesting stainless steel, monel, or nickel packaging. Exceptions for the number of aluminum and steel sample packagings require approval from the Pipeline and Hazardous Materials Safety Administration (PHMSA). Notwithstanding the provisions of178.602(a) of this subpart, combination packagings may be subjected to the stacking test without their inner packagings, except where this would invalidate the test results.
The test sample must be subjected to a force applied to the top surface of the test sample equivalent to the total weight of identical packages that might be stacked on it during transport. The minimum height of the stack, including the test sample, must be 3.0 m (10 feet). The duration of the test must be 24 hours, except that plastic drums, jerricans, and composite packaging 6HH, intended for liquids, shall be subjected to the stacking test for a period of 28 days at a temperature of not less than 40°C (104°F).
Alternative test methods that yield equivalent results may be used if the Associate Administrator approves. In guided load tests, stacking stability must be assessed after completion of the test by placing two filled packagings of the same type on the test sample. The stacked packages must maintain their position for one hour. Plastic packagings must be cooled to ambient temperature beforehand.
Periodic retesting must take place in accordance with 178.606(c)(1) or using a dynamic compression testing machine that meets the specifications of that section.
Passing the test
No test sample may leak. In composite packagings or combination packagings, there must be no leakage of the filling substance from the inner receptacle, or inner packaging. No test sample may show any deterioration that could adversely affect transportation safety or any distortion likely to:
For the dynamic compression test, a container passes the test if, after application of the required load, there is no buckling of the sidewalls sufficient to cause damage to its expected contents. In no case, may the maximum deflection exceed one inch.
Each packaging must be capable of withstanding, without rupture or leakage, this vibration test procedure:
Other equally effective methods can be used if approved by the Associate Administrator for Hazardous Materials Safety.
Passing the test
A packaging passes the vibration test if there is no rupture or leakage from any of the packages. No test sample should show any deterioration that could adversely affect transportation safety or any distortion liable to reduce packaging strength.
Unless otherwise specified, in order for a person to offer a hazardous material for transportation in a packaging authorized by an exemption/special permit, the person must be “the holder of” or “party to” the exemption/special permit.
If an exemption/special permit authorizes the use of a packaging for the shipment or transportation of a hazardous material by any person or class of persons other than or in addition to the holder of the exemption/special permit, that person or a member of the specified class of persons may use the packaging for the purposes authorized in the exemption/special permit subject to the terms specified in the exemption/special permit.
Copies of exemption/special permits may be obtained by accessing the Pipeline and Hazardous Materials Safety Administration (PHMSA) website or calling the Office of Hazardous Materials Special Permits and Approvals at (202) 366-4433.
When an exemption/special permit issued to a person who offers a hazardous material contains requirements that apply to a carrier of the hazardous material, the offeror must furnish a copy of the exemption/special permit to the carrier before or at the time a shipment is tendered. Notes: An exemption/special permit is different from an exception.
An exemption/special permit is a statement from PHMSA authorizing a person or persons to use a packaging other than specifically indicated in the Hazardous Materials Regulations (HMR). A company, in most cases, must apply to get, use, or be allowed to use (be a party to) an existing exemption/special permit.
In some cases, an exemption/special permit may be given to an unnamed group or a category of persons meeting certain criteria. This type of exemption/special permit allows broader use but may only be utilized when the involved parties are fully aware of the conditions required in the exemption/special permit and only if a copy of the exemption/special permit is maintained at the location using it.
An exception is a statement of conditions listed in the HMR, that allows any person who meets them to be excepted from certain requirements of the HMR. Meeting the criteria for an exception excepts a company from some or all of the HMR’s requirements. Which requirements are excepted will be specifically indicated in the wording of the exception.
United Nations (UN) or performance-oriented packaging are non-bulk packagings—except cylinders—that have successfully passed applicable performance tests: Drop Test, Leakproofness Test, Hydrostatic Pressure Test, Stacking Test, and the Vibration Standard.
Manufacturers must mark all authorized packagings (specification or performance-oriented) as required by Parts 178 and 179 of the Hazardous Materials Regulations (HMR). This marking is the manufacturer’s certification that the packaging has been manufactured and tested in accordance with Parts 178 and 179.
The United Nations (UN) markings tell the user many things, including what type of packaging it is and to what level of testing it has passed. The marking must be durable, legible, and clearly visible. The marking must include:
Examples:
This is a fiberboard box (4G), tested for Packing Groups II and III (Y), with a maximum mass of 145 kilograms, designed to contain an inner packaging(S), and manufactured in 1983 (83). It was manufactured in the United States (USA) by a manufacturer whose registered symbol is “RA.”
This is a steel non-removable head drum (1A1) designed as a single package for liquids, tested for Packing Groups II and III (Y) for materials with a specific gravity up to 1.4, hydrostatically tested to 150 kPa, and manufactured in 1983 (83). The drum was manufactured in the United States (USA) by a manufacturer whose registered symbol is “VL824.” The minimum thickness of the material is 1 millimeter.
This marking indicates a steel, non-removable head drum (1A1), designed as a single packaging for liquids, tested for Packing Groups II and III (Y), for materials with a specific gravity of 1.4. It was hydrostatically tested to 150 kPa and was manufactured in 1992 (92). The drum was reconditioned in the United States (USA) by a reconditioner whose registered symbol is “RB” in 1993 (93). The drum was reconditioned (R) and successfully passed the leak proofness test (L).
Any packaging required by the Hazardous Materials Regulations to conform to a UN standard must be marked in a manner such as illustrated above.
United Nations (UN) or performance-oriented packaging are non-bulk packagings—except cylinders—that have successfully passed applicable performance tests: Drop Test, Leakproofness Test, Hydrostatic Pressure Test, Stacking Test, and the Vibration Standard.
Manufacturers must mark all authorized packagings (specification or performance-oriented) as required by Parts 178 and 179 of the Hazardous Materials Regulations (HMR). This marking is the manufacturer’s certification that the packaging has been manufactured and tested in accordance with Parts 178 and179.
The more hazardous the material, the more restrictive the packaging requirements will be. This is not just determined by the hazard class, but also by the degree of hazard, i.e., the packing group.
Example: Not all flammable liquids present the same degree of danger, and the packaging requirements recognize this. The packaging requirements for a Packing Group I, Class 3 (flammable) material (initial boiling point less than or equal to 35°C) are more restrictive than for a Packing Group II, Class 3 material (flashpoint less than 23°C, initial boiling point greater than 35°C).
Packaging test requirements are more or less restrictive depending upon the Packing Group of the material for which the package is to be used.
Example: For a material with a specific gravity £1.2, the drop height for Packing Group I is 1.8 m (5.9 feet), Packing Group II is 1.2 m (3.9 feet) and Packing Group III is 0.8 m (2.6 feet). For a material with a specific gravity >1.2, a formula exists for each packing group that is to be used in determining the drop height.
All packages or packaging (bulk and non-bulk) must comply with the “General requirements for packagings and packages” (173.24), including: new and reused packagings, and specification and non-specification packages, unless excepted. These requirements are in addition to those that Part 178 spells out. In addition, non-bulk packagings and packages must also be in compliance with the requirements of 173.24a “Additional general requirements for non-bulk packagings and packages,” and bulk packagings with the requirements of 173.24b “Additional general requirements for bulk packagings.”
It is the responsibility of the person offering a hazardous material for transportation to ensure that the packagings are compatible with the hazardous material they are used for. This particularly applies to corrosivity, permeability, softening, premature aging, and embrittlement.
Packaging materials and contents must be such that there will be no significant chemical or galvanic reaction between the materials and contents of the package.
Plastic packagings and receptacles
Plastic used in packagings and receptacles must be of a type compatible with the hazardous material the packaging will be used for and may not be permeable to an extent that a hazardous condition is likely to occur during transportation, handling, or refilling.
Each plastic packaging or receptacle which is used for liquid hazardous materials must be capable of withstanding without failure the procedure specified in Appendix B of Part 173 - Procedure for Testing Chemical Compatibility and Rate of Permeation in Plastic Packagings and Receptacles. See Section 173.24(e)(3)(ii) and (iii) for more specific information about required testing results.
Compatibility
Hazardous materials may not be packed or mixed together in the same outer packaging with other hazardous or nonhazardous materials if such materials are capable of reacting dangerously with each other and causing:
Packagings for solids which may change state during transportation
Packagings used for solids, which may become liquid at temperatures likely to be encountered during transportation, must be capable of containing the hazardous material in the liquid state.
Closures
Closures must be designed and closed that under conditions such as changes in temperature, pressure, and vibration which are normally encountered in transportation:
A closure, including gaskets or other closure components, if any, used on a specification packaging must conform to all applicable requirements of the specification, except as otherwise provided in the HMR.
Venting
Venting of packagings, to reduce internal pressure which may develop by the evolution of gas from the contents, is permitted only when:
IBCs may be vented when required and must be of a type that has successfully passed applicable design qualification tests with no release of hazmat.
Outage and filling limits
When filling packagings and receptacles for liquids, sufficient ullage (outage) must be left to ensure that neither leakage nor permanent distortion of the packaging or receptacle will occur as a result of an expansion of the liquid caused by temperatures likely to be encountered during transportation.
Requirements for outage and filling limits for non-bulk and bulk packagings are specified in Section 173.24a(d) and 173.24b(a), respectively.
Filling limits for compressed gases and cryogenic liquids are specified in Section 173.301 through 173.306 for cylinders and 173.314 through 173.319 for bulk packagings.
Air transportation
Packages offered or intended for transportation by aircraft are subject to requirements additional to those of other modes of transport and must conform to the general requirements for transportation by aircraft in 173.27.
Additional information concerning packaging requirements for preparation of hazardous materials are found in other sections of the HMR.
Packagings and receptacles used more than once must be in such condition, including closure devices and cushioning materials, that they conform in all respects to the prescribed requirements of the Hazardous Materials Regulations (HMR). Before reuse, each packaging must be inspected and may not be reused unless free from incompatible residue, rupture, or other damage which reduces its structural integrity.
A non-bulk packaging used more than once must conform to the provisions and limitations detailed in Section 173.28(b).
What is reconditioning?
Reconditioning of metal drums according to the HMR means:
Packagings that have visible pitting, significant reduction in material thickness, metal fatigue, damaged threads or closures, or other significant defects, must be rejected.
Reconditioning of a non-bulk packaging other than a metal drum is restoring the packaging by repair or replacement of non-integral packaging components (such as removable gaskets, closure devices, cushioning material, etc.) to a condition such that it conforms in all respects with the prescribed requirements of the HMR.
For a United Nations (UN) 1H1 plastic drum, replacing a removable gasket or closure device with a replacement of the same design and material which provides equivalent performance does not constitute reconditioning. Packagings which have significant unrepairable defects may not be reused.
A person who reconditions a packaging manufactured and marked under the provisions of Subpart L of Part 178 of the HMR, must mark that packaging as required by Section 178.503(c) and (d). The marking is the certification of the reconditioner that the packaging conforms to the standard for which it is marked and that all functions performed by the reconditioner which are prescribed by the HMR have been performed in compliance with the HMR.
The markings applied by the reconditioner may be different from those applied by the manufacturer at the time of original manufacture but may not identify a greater performance capability than that for which the original design type had been tested. For example, the reconditioner may mark a drum which was originally marked as 1A1/Y1.8 as 1A1/Y1.2 or 1A1/Z2.0.
What is remanufacturing?
Remanufacturing of non-bulk packagings for the purpose of the HMR, is:
A person who remanufactures a non-bulk packaging to conform to a specification or standard in Part 178 of the HMR is subject to the requirements ofPart 178 of the HMR as a manufacturer.
What does NRC mean?
A packaging marked as NRC (non-reusable container) according to the Department of Transportation (DOT) specification or UN standard requirements in Part 178 of the HMR may be reused for the shipment of any material not required by the HMR to be shipped in a DOT specification or UN standard packaging.
Notes: The requirements for reuse of packagings are very specific. Be sure to include a thorough discussion of these guidelines in all function-specific training if a company reuses, reconditions, or remanufactures packagings.
Unless specifically indicated otherwise, a person must follow certain guidelines to offer a hazardous material for transportation in a packaging or container required by Part 173 of the Hazardous Materials Regulations (HMR).
The person who offers the hazardous material is required:
What is a packaging?
According to the definition in Section 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 packing requirements of the HMR.
The following marks may be used to determine whether or not the packaging is authorized:
DOT specification or UN standard packagings
A person who offers a DOT specification or UN standard packaging that is subject to the requirements in Part 178 of the HMR is required to perform all functions necessary to bring that package into compliance with Parts 173 and 178 of the HMR, as identified by the packaging manufacturer or subsequent distributor, in accordance with Section 178.2 of the HMR.
Shipments of fissile radioactive materials, and Type B or highway route controlled quantity packages of radioactive materials
The shipper is required to notify the consignee of the dates of shipment and expected arrival. The shipper must also notify each consignee of any special loading/unloading instructions prior to the first shipment.
Shipments of irradiated reactor fuel
The shipper must provide physical protection in compliance with a plan established under either:
Notes: The shipper’s certification on a shipping paper for transportation of hazardous materials requires the shipper to certify that the above-named materials are properly classified, described, packaged, marked and labeled, and are in proper condition for transportation according to the applicable regulations of the DOT.
The shipper, or the person or employee of the person who originates the shipment for transportation is responsible for properly preparing the hazardous material for transportation. The hazardous material must be properly classified to ensure that it is prepared using the proper packaging, marking(s), and label(s). If a company is a shipper of hazardous material, it is responsible to understand the preparation requirements including all applicable packaging related requirements.
Specific types of packagings have different requirements for hazardous materials transportation. Hazardous Materials Regulations (HMR) define the terms and requirements for:
Common types of bulk packagings include cargo tanks, portable tanks, intermediate bulk containers (IBCs), and tank cars.
Common types of non-bulk packagings include boxes, drums, barrels, jerricans, pails, bags, composite packagings, and cylinders.
The regulations include maximum capacity, maximum net mass, and water capacity. Empty packaging must conform to certain provisions or be subject to other requirements of the HMR.
A bulk packaging is a packaging in which hazardous materials are loaded with no intermediate form of containment AND has:
Bulk packaging does not include a vessel or barge. Bulk packaging does include transport vehicles and freight containers. Common types of bulk packagings include cargo tanks, portable tanks, intermediate bulk containers (IBCs), and tank cars.
Bulk packaging is a term that is used throughout the Hazardous Materials Regulations. Knowing if a hazmat package is bulk or non-bulk is an essential piece of knowledge when determining what requirements in the regulations apply to the shipment.
A cargo tank is a bulk packaging that is a tank intended primarily for the carriage of liquids or gases. The cargo tank includes appurtenances, reinforcements, fittings, and closures. A cargo tank is not fabricated under a specification for cylinders, intermediate bulk containers, portable tanks, multi-unit tank car tanks, or tank cars.
A cargo tank is permanently attached to or forms a part of a motor vehicle, or is not permanently attached to a motor vehicle but which, by reason of its size, construction or attachment is loaded or unloaded without being removed from the motor vehicle. The definition for cargo tank can be found in 171.8.
Common specification cargo tanks include MC 306, MC 307, MC 312, DOT 406, DOT 407, and DOT 412. The specifications for construction of cargo tanks can be found in Part 178, subpart J of the Hazardous Materials Regulations.
Cargo tanks are required to undergo certain tests and inspections.
Cargo tanks are required to be properly marked and placarded for transport.
A portable tank is a bulk packaging (except a cylinder having a water capacity of 1000 pounds or less) designed primarily to be loaded onto, or on, or temporarily attached to a transport vehicle or ship and equipped with skids, mountings, or accessories to facilitate handling of the tank by mechanical means. It does not include a cargo tank, tank car, multi-unit tank car tank, or trailer carrying 3AX, 3AAX or 3T cylinders. The definition for portable tank can be found in 171.8.
The specifications for construction of portable tanks can be found in Part 178, subpart H of the Hazardous Materials Regulations. Portable tanks include Department of Transportation (DOT) specification portable tanks, intermodal (IM) portable tanks and United Nations (UN) portable tanks.
Portable tanks are required to undergo certain tests and inspections. For more information see 178.276,178.277, and Part 180, subpart G.
Portable tanks are required to be properly marked, labeled or placarded for transport. For information on these topics see the ezExplanations Markings, Labeling, and Placarding.
An intermediate bulk container (IBC) is a rigid or flexible portable packaging, other than a cylinder or portable tank, which is designed for mechanical handling. The definition for intermediate bulk container can be found in 171.8.
The specifications for construction of intermediate bulk containers can be found in Part 178,subparts N and O of the Hazardous Materials Regulations.
Intermediate bulk containers are required to undergo certain tests and inspections. For more information see Part 180, subpart D.
Intermediate bulk containers are required to be properly marked, labeled or placarded for transport. For information on these topics see the ezExplanations Markings, Labeling, and Placarding.
A non-bulk packaging is a packaging which has:
The definition for non-bulk packaging can be found in 171.8.
Common types of non-bulk packagings include boxes, drums, barrels, jerricans, pails, bags, composite packagings, and cylinders.
Non-bulk packagings that meet the manufacturing requirements in the regulations must be marked with the appropriate United Nations (UN) marking specified in 178.503 or for cylinders the markings specified in Part 178, subpart C.
Non-bulk packaging is a term that is used throughout the Hazardous Materials Regulations. Knowing if a hazmat package is bulk or non-bulk is an essential piece of knowledge when determining what requirements in the regulations apply to the shipment.
The following design requirements apply to non-bulk packages, except as provided for liquid hazardous materials in non-bulk packagings, as detailed in Section 172.312.
A single or composite non-bulk packaging may be filled with a liquid hazardous material only when the specific gravity of the material does not exceed that marked on the packaging, or a specific gravity of 1.2 if not marked, with the following exceptions:
A non-bulk packaging may not be filled with a hazardous material to a gross mass greater than the maximum gross mass marked on the packaging, unless otherwise allowed in Section 173.24a.
Packagings tested with hydrostatic test pressure as prescribed in Section 178.605.
Packagings tested as prescribed in Section 178.503(a)(5) of the Hazardous Materials Regulations (HMR) may be used for liquids only when the vapor pressure of the liquid conforms to one of the following:
No hazardous material may remain on the outside of a package after filling.
An outer non-bulk packaging may contain more than one hazardous material only when:
A packaging containing inner packagings of Division 6.2 materials may not contain other hazardous materials, except dry ice.
Liquids must not completely fill a receptacle at a temperature of 55 degrees C (131 degrees F) or less.
A cylinder is a pressure vessel designed for pressure higher than 40 psia (pounds per square inch absolute) and has a circular cross section. It does not include a portable tank, multi-unit tank car tank, tank car, or cargo tank. The definition for cylinder can be found in 171.8.
The specifications for construction of cylinders can be found in Part 178, subpart C of the Hazardous Materials Regulations (HMR).
Cylinders are required to undergo certain tests and inspections. For more information see Part 180, subpart C.
Cylinders are required to be properly marked and labeled for transport. Placards may be required for transporting certain loads of cylinders.
What is an overpack? According to the definition in Section 171.8:
An 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, except as provided in Subpart K of Part 178. An overpack does not include a transport vehicle, freight container, or aircraft unit load device.
Examples of overpacks are one or more packages:
Authorized packages containing hazardous materials may be offered for transportation in an overpack as defined in Section 171.8 of the Hazardous Materials Regulations (HMR), if all of the following conditions are met:
Shrink-wrapped or stretch-wrapped trays may be used as outer packagings for inner packagings prepared in accordance with the limited quantity provisions or consumer commodity provisions of the HMR, provided that the inner packagings are not fragile, liable to break or be easily punctured. Each package may not exceed 20 kg (44 lbs) gross weight.
Hazardous materials which are required to be labeled “POISON” may be transported in the same motor vehicle with material that is marked or known to be foodstuffs, feed or any edible material intended for consumption by humans or animals provided the hazardous materials:
Notes: An overpack is generally thought of as being an outer enclosure containing a package or packages. Authorized overpacks for use in combination packagings will be discussed in more detail in the topic: Hazmat - Non-bulk Packagings.
A non-bulk packaging is a packaging which has:
The definition for non-bulk packaging can be found in 171.8.
Common types of non-bulk packagings include boxes, drums, barrels, jerricans, pails, bags, composite packagings, and cylinders.
Non-bulk packagings that meet the manufacturing requirements in the regulations must be marked with the appropriate United Nations (UN) marking specified in 178.503 or for cylinders the markings specified in Part 178, Subpart C.
Non-bulk packaging is a term that is used throughout the Hazardous Materials Regulations. Knowing if a hazmat package is bulk or non-bulk is an essential piece of knowledge when determining what requirements in the regulations apply to the shipment.
An empty packaging containing only the residue of a hazardous material must be offered for transportation and transported in the same manner as when it previously contained a greater quantity of that hazardous material, unless otherwise provided in Section 173.29.
An empty packaging is not subject to any other requirements of the Hazardous Materials Regulations (HMR) if it conforms to the following provisions:
A non-bulk packaging containing only the residue of a hazardous material covered by Table 2 of Section 172.504 of the HMR:
Provisions for describing an empty packaging on a shipping paper are detailed in Section 172.203(e). A package which contains a residue of an elevated temperature material may remain marked in the same manner as when it contained a greater quantity of the materials even though it no longer meets the definition in Section 171.8 for an elevated temperature material.
Note: It is important to note that unless all traces of the hazardous material have been removed, the packaging still possesses the hazard of that material and as such still poses a risk in transportation.
Specific types of packagings have different requirements for hazardous materials transportation. Hazardous Materials Regulations (HMR) define the terms and requirements for:
Common types of bulk packagings include cargo tanks, portable tanks, intermediate bulk containers (IBCs), and tank cars.
Common types of non-bulk packagings include boxes, drums, barrels, jerricans, pails, bags, composite packagings, and cylinders.
The regulations include maximum capacity, maximum net mass, and water capacity. Empty packaging must conform to certain provisions or be subject to other requirements of the HMR.
Unless specifically indicated otherwise, a person must follow certain guidelines to offer a hazardous material for transportation in a packaging or container required by Part 173 of the Hazardous Materials Regulations (HMR).
The person who offers the hazardous material is required:
What is a packaging?
According to the definition in Section 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 packing requirements of the HMR.
The following marks may be used to determine whether or not the packaging is authorized:
DOT specification or UN standard packagings
A person who offers a DOT specification or UN standard packaging that is subject to the requirements in Part 178 of the HMR is required to perform all functions necessary to bring that package into compliance with Parts 173 and178 of the HMR, as identified by the packaging manufacturer or subsequent distributor, in accordance with Section 178.2 of the HMR.
Shipments of fissile radioactive materials, and Type B or highway route controlled quantity packages of radioactive materials
The shipper is required to notify the consignee of the dates of shipment and expected arrival. The shipper must also notify each consignee of any special loading/unloading instructions prior to the first shipment.
Shipments of irradiated reactor fuel
The shipper must provide physical protection in compliance with a plan established under either:
Notes: The shipper’s certification on a shipping paper for transportation of hazardous materials requires the shipper to certify that the above-named materials are properly classified, described, packaged, marked and labeled, and are in proper condition for transportation according to the applicable regulations of the DOT.
The shipper, or the person or employee of the person who originates the shipment for transportation is responsible for properly preparing the hazardous material for transportation. The hazardous material must be properly classified to ensure that it is prepared using the proper packaging, marking(s), and label(s). If a company is a shipper of hazardous material, it is responsible to understand the preparation requirements including all applicable packaging related requirements.
Hazardous materials can only be transported in packaging that are authorized by the Hazardous Materials Regulations (HMR). The packaging authorized in Part 173 can only be used for a hazardous material if the section in Part 173 is referenced in Column 8 of the Hazardous Materials Table for the proper shipping name chosen for the material.
Part 173 provides detailed packaging rules for each class of hazardous materials. The packaging requirements set for a specific hazardous material are the same for all modes of transportation unless otherwise stated or exceptions are authorized.
Specification packaging are cylinders, portable tanks, cargo tanks, and tank car tanks for which the Department of Transportation (DOT) has issued detailed manufacturing specifications.
Manufacturers must mark all authorized packagings as required by Parts 178 and 179 of the Hazardous Materials Regulations (HMR). This marking is the manufacturer’s certification that the packaging has been manufactured and tested in accordance with Parts 178 and 179.
At periodic intervals and whenever a company needs to qualify a package design, it must perform drop tests from distances between 2.2 feet and 5.9 feet, as specified in 178.601(e) and 178.603. For other than flat drops, the center of gravity of the test packaging must be vertically over the point of impact.
To periodically test single or composite packagings constructed of stainless steel, nickel, or money, the drop test may be conducted with two samples—one sample each for the two drop orientations. The regulations allow companies to use samples that may have previously been used for the hydrostatic pressure or stacking test.
For details about exceptions for the number of steel and aluminum packaging samples used for conducting the drop test, contact the Pipeline and Hazardous Materials Safety Administration (PHMSA).
Passing the test
A package is considered to successfully pass the drop tests if, for each sample tested:
Using compressed air or other suitable gases, a company must perform a leakproofness test on all packagings intended to contain liquids. The packaging must pass the test — i.e., no air leaks from the packaging — before being used in transportation and before any reuse authorized under 173.28. Normally, three samples of each different packaging must be tested.
For design qualification and periodic testing, packagings must be tested with closures in place. For production testing, however, this is not necessary, and removable heads need not be installed, either. For testing with closures in place, vented closures must either be replaced by similar non-vented closures, or the vent must be sealed.
In testing, the packaging must be restrained under water while an internal air pressure is applied, and the method of restraint must not affect the results of the test. The test must be conducted, for other than production testing, for a minimum time of five minutes. Other methods, at least equally effective, may be used in accordance with Appendix B of Part 178.
An internal air pressure (gauge) must be applied to the packaging as indicated for the following packing groups:
Passing the test
A packaging passes the leakproofness test if there is no leakage of air from the packaging.
At periodic intervals and whenever qualifying a metal, plastic, and composite packaging design type intended to contain liquids, a company must perform the hydrostatic pressure test as specified in 178.601(e) and 178.605, and no leakage can occur. This test is not required, however, for inner packagings of combination packagings. For internal pressure requirements for inner packagings of combination packagings intended for transportation by aircraft, see 173.27(c).
Normally, the regulations require three test samples for each different packaging — although one will suffice for packagings constructed of stainless steel, monel, or nickel. Other exceptions require approval from the Pipeline and Hazardous Materials Safety Administration (PHMSA).
Replace vented closures with similar non-vented closures or seal the vent during the test.
Metal packagings and composite packagings other than plastic (e.g., glass, porcelain or stoneware), including their closures, must be subjected to the test pressure for five minutes. Plastic packagings and composite packagings (plastic material), including their closures, must be subjected to the test pressure for 30 minutes.
This pressure is the one to be marked as required in 178.503(a)(5) of this part. The receptacles must be supported in a manner that does not invalidate the test. The test pressure — as specified in detail in 178.605(d) — must be applied continuously and evenly, and it must be kept constant throughout the test period.
Passing the test
A packaging passes the hydrostatic test if, for each sample, there is no leakage of liquid from the packaging.
All packaging design types, other than bags, must be subjected to a stacking test. The regulations require three test samples for each different packaging — except for one each for periodic retesting stainless steel, monel, or nickel packaging. Exceptions for the number of aluminum and steel sample packagings require approval from the Pipeline and Hazardous Materials Safety Administration (PHMSA). Notwithstanding the provisions of178.602(a) of this subpart, combination packagings may be subjected to the stacking test without their inner packagings, except where this would invalidate the test results.
The test sample must be subjected to a force applied to the top surface of the test sample equivalent to the total weight of identical packages that might be stacked on it during transport. The minimum height of the stack, including the test sample, must be 3.0 m (10 feet). The duration of the test must be 24 hours, except that plastic drums, jerricans, and composite packaging 6HH, intended for liquids, shall be subjected to the stacking test for a period of 28 days at a temperature of not less than 40°C (104°F).
Alternative test methods that yield equivalent results may be used if the Associate Administrator approves. In guided load tests, stacking stability must be assessed after completion of the test by placing two filled packagings of the same type on the test sample. The stacked packages must maintain their position for one hour. Plastic packagings must be cooled to ambient temperature beforehand.
Periodic retesting must take place in accordance with 178.606(c)(1) or using a dynamic compression testing machine that meets the specifications of that section.
Passing the test
No test sample may leak. In composite packagings or combination packagings, there must be no leakage of the filling substance from the inner receptacle, or inner packaging. No test sample may show any deterioration that could adversely affect transportation safety or any distortion likely to:
For the dynamic compression test, a container passes the test if, after application of the required load, there is no buckling of the sidewalls sufficient to cause damage to its expected contents. In no case, may the maximum deflection exceed one inch.
Each packaging must be capable of withstanding, without rupture or leakage, this vibration test procedure:
Other equally effective methods can be used if approved by the Associate Administrator for Hazardous Materials Safety.
Passing the test
A packaging passes the vibration test if there is no rupture or leakage from any of the packages. No test sample should show any deterioration that could adversely affect transportation safety or any distortion liable to reduce packaging strength.
Unless otherwise specified, in order for a person to offer a hazardous material for transportation in a packaging authorized by an exemption/special permit, the person must be “the holder of” or “party to” the exemption/special permit.
If an exemption/special permit authorizes the use of a packaging for the shipment or transportation of a hazardous material by any person or class of persons other than or in addition to the holder of the exemption/special permit, that person or a member of the specified class of persons may use the packaging for the purposes authorized in the exemption/special permit subject to the terms specified in the exemption/special permit.
Copies of exemption/special permits may be obtained by accessing the Pipeline and Hazardous Materials Safety Administration (PHMSA) website or calling the Office of Hazardous Materials Special Permits and Approvals at (202) 366-4433.
When an exemption/special permit issued to a person who offers a hazardous material contains requirements that apply to a carrier of the hazardous material, the offeror must furnish a copy of the exemption/special permit to the carrier before or at the time a shipment is tendered. Notes: An exemption/special permit is different from an exception.
An exemption/special permit is a statement from PHMSA authorizing a person or persons to use a packaging other than specifically indicated in the Hazardous Materials Regulations (HMR). A company, in most cases, must apply to get, use, or be allowed to use (be a party to) an existing exemption/special permit.
In some cases, an exemption/special permit may be given to an unnamed group or a category of persons meeting certain criteria. This type of exemption/special permit allows broader use but may only be utilized when the involved parties are fully aware of the conditions required in the exemption/special permit and only if a copy of the exemption/special permit is maintained at the location using it.
An exception is a statement of conditions listed in the HMR, that allows any person who meets them to be excepted from certain requirements of the HMR. Meeting the criteria for an exception excepts a company from some or all of the HMR’s requirements. Which requirements are excepted will be specifically indicated in the wording of the exception.
United Nations (UN) or performance-oriented packaging are non-bulk packagings—except cylinders—that have successfully passed applicable performance tests: Drop Test, Leakproofness Test, Hydrostatic Pressure Test, Stacking Test, and the Vibration Standard.
Manufacturers must mark all authorized packagings (specification or performance-oriented) as required by Parts 178 and 179 of the Hazardous Materials Regulations (HMR). This marking is the manufacturer’s certification that the packaging has been manufactured and tested in accordance with Parts 178 and 179.
The United Nations (UN) markings tell the user many things, including what type of packaging it is and to what level of testing it has passed. The marking must be durable, legible, and clearly visible. The marking must include:
Examples:
This is a fiberboard box (4G), tested for Packing Groups II and III (Y), with a maximum mass of 145 kilograms, designed to contain an inner packaging(S), and manufactured in 1983 (83). It was manufactured in the United States (USA) by a manufacturer whose registered symbol is “RA.”
This is a steel non-removable head drum (1A1) designed as a single package for liquids, tested for Packing Groups II and III (Y) for materials with a specific gravity up to 1.4, hydrostatically tested to 150 kPa, and manufactured in 1983 (83). The drum was manufactured in the United States (USA) by a manufacturer whose registered symbol is “VL824.” The minimum thickness of the material is 1 millimeter.
This marking indicates a steel, non-removable head drum (1A1), designed as a single packaging for liquids, tested for Packing Groups II and III (Y), for materials with a specific gravity of 1.4. It was hydrostatically tested to 150 kPa and was manufactured in 1992 (92). The drum was reconditioned in the United States (USA) by a reconditioner whose registered symbol is “RB” in 1993 (93). The drum was reconditioned (R) and successfully passed the leak proofness test (L).
Any packaging required by the Hazardous Materials Regulations to conform to a UN standard must be marked in a manner such as illustrated above.
United Nations (UN) or performance-oriented packaging are non-bulk packagings—except cylinders—that have successfully passed applicable performance tests: Drop Test, Leakproofness Test, Hydrostatic Pressure Test, Stacking Test, and the Vibration Standard.
Manufacturers must mark all authorized packagings (specification or performance-oriented) as required by Parts 178 and 179 of the Hazardous Materials Regulations (HMR). This marking is the manufacturer’s certification that the packaging has been manufactured and tested in accordance with Parts 178 and179.
The more hazardous the material, the more restrictive the packaging requirements will be. This is not just determined by the hazard class, but also by the degree of hazard, i.e., the packing group.
Example: Not all flammable liquids present the same degree of danger, and the packaging requirements recognize this. The packaging requirements for a Packing Group I, Class 3 (flammable) material (initial boiling point less than or equal to 35°C) are more restrictive than for a Packing Group II, Class 3 material (flashpoint less than 23°C, initial boiling point greater than 35°C).
Packaging test requirements are more or less restrictive depending upon the Packing Group of the material for which the package is to be used.
Example: For a material with a specific gravity £1.2, the drop height for Packing Group I is 1.8 m (5.9 feet), Packing Group II is 1.2 m (3.9 feet) and Packing Group III is 0.8 m (2.6 feet). For a material with a specific gravity >1.2, a formula exists for each packing group that is to be used in determining the drop height.
All packages or packaging (bulk and non-bulk) must comply with the “General requirements for packagings and packages” (173.24), including: new and reused packagings, and specification and non-specification packages, unless excepted. These requirements are in addition to those that Part 178 spells out. In addition, non-bulk packagings and packages must also be in compliance with the requirements of 173.24a “Additional general requirements for non-bulk packagings and packages,” and bulk packagings with the requirements of 173.24b “Additional general requirements for bulk packagings.”
It is the responsibility of the person offering a hazardous material for transportation to ensure that the packagings are compatible with the hazardous material they are used for. This particularly applies to corrosivity, permeability, softening, premature aging, and embrittlement.
Packaging materials and contents must be such that there will be no significant chemical or galvanic reaction between the materials and contents of the package.
Plastic packagings and receptacles
Plastic used in packagings and receptacles must be of a type compatible with the hazardous material the packaging will be used for and may not be permeable to an extent that a hazardous condition is likely to occur during transportation, handling, or refilling.
Each plastic packaging or receptacle which is used for liquid hazardous materials must be capable of withstanding without failure the procedure specified in Appendix B of Part 173 - Procedure for Testing Chemical Compatibility and Rate of Permeation in Plastic Packagings and Receptacles. See Section 173.24(e)(3)(ii) and (iii) for more specific information about required testing results.
Compatibility
Hazardous materials may not be packed or mixed together in the same outer packaging with other hazardous or nonhazardous materials if such materials are capable of reacting dangerously with each other and causing:
Packagings for solids which may change state during transportation
Packagings used for solids, which may become liquid at temperatures likely to be encountered during transportation, must be capable of containing the hazardous material in the liquid state.
Closures
Closures must be designed and closed that under conditions such as changes in temperature, pressure, and vibration which are normally encountered in transportation:
A closure, including gaskets or other closure components, if any, used on a specification packaging must conform to all applicable requirements of the specification, except as otherwise provided in the HMR.
Venting
Venting of packagings, to reduce internal pressure which may develop by the evolution of gas from the contents, is permitted only when:
IBCs may be vented when required and must be of a type that has successfully passed applicable design qualification tests with no release of hazmat.
Outage and filling limits
When filling packagings and receptacles for liquids, sufficient ullage (outage) must be left to ensure that neither leakage nor permanent distortion of the packaging or receptacle will occur as a result of an expansion of the liquid caused by temperatures likely to be encountered during transportation.
Requirements for outage and filling limits for non-bulk and bulk packagings are specified in Section 173.24a(d) and 173.24b(a), respectively.
Filling limits for compressed gases and cryogenic liquids are specified in Section 173.301 through 173.306 for cylinders and 173.314 through 173.319 for bulk packagings.
Air transportation
Packages offered or intended for transportation by aircraft are subject to requirements additional to those of other modes of transport and must conform to the general requirements for transportation by aircraft in 173.27.
Additional information concerning packaging requirements for preparation of hazardous materials are found in other sections of the HMR.
Packagings and receptacles used more than once must be in such condition, including closure devices and cushioning materials, that they conform in all respects to the prescribed requirements of the Hazardous Materials Regulations (HMR). Before reuse, each packaging must be inspected and may not be reused unless free from incompatible residue, rupture, or other damage which reduces its structural integrity.
A non-bulk packaging used more than once must conform to the provisions and limitations detailed in Section 173.28(b).
What is reconditioning?
Reconditioning of metal drums according to the HMR means:
Packagings that have visible pitting, significant reduction in material thickness, metal fatigue, damaged threads or closures, or other significant defects, must be rejected.
Reconditioning of a non-bulk packaging other than a metal drum is restoring the packaging by repair or replacement of non-integral packaging components (such as removable gaskets, closure devices, cushioning material, etc.) to a condition such that it conforms in all respects with the prescribed requirements of the HMR.
For a United Nations (UN) 1H1 plastic drum, replacing a removable gasket or closure device with a replacement of the same design and material which provides equivalent performance does not constitute reconditioning. Packagings which have significant unrepairable defects may not be reused.
A person who reconditions a packaging manufactured and marked under the provisions of Subpart L of Part 178 of the HMR, must mark that packaging as required by Section 178.503(c) and (d). The marking is the certification of the reconditioner that the packaging conforms to the standard for which it is marked and that all functions performed by the reconditioner which are prescribed by the HMR have been performed in compliance with the HMR.
The markings applied by the reconditioner may be different from those applied by the manufacturer at the time of original manufacture but may not identify a greater performance capability than that for which the original design type had been tested. For example, the reconditioner may mark a drum which was originally marked as 1A1/Y1.8 as 1A1/Y1.2 or 1A1/Z2.0.
What is remanufacturing?
Remanufacturing of non-bulk packagings for the purpose of the HMR, is:
A person who remanufactures a non-bulk packaging to conform to a specification or standard in Part 178 of the HMR is subject to the requirements ofPart 178 of the HMR as a manufacturer.
What does NRC mean?
A packaging marked as NRC (non-reusable container) according to the Department of Transportation (DOT) specification or UN standard requirements in Part 178 of the HMR may be reused for the shipment of any material not required by the HMR to be shipped in a DOT specification or UN standard packaging.
Notes: The requirements for reuse of packagings are very specific. Be sure to include a thorough discussion of these guidelines in all function-specific training if a company reuses, reconditions, or remanufactures packagings.
Unless specifically indicated otherwise, a person must follow certain guidelines to offer a hazardous material for transportation in a packaging or container required by Part 173 of the Hazardous Materials Regulations (HMR).
The person who offers the hazardous material is required:
What is a packaging?
According to the definition in Section 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 packing requirements of the HMR.
The following marks may be used to determine whether or not the packaging is authorized:
DOT specification or UN standard packagings
A person who offers a DOT specification or UN standard packaging that is subject to the requirements in Part 178 of the HMR is required to perform all functions necessary to bring that package into compliance with Parts 173 and 178 of the HMR, as identified by the packaging manufacturer or subsequent distributor, in accordance with Section 178.2 of the HMR.
Shipments of fissile radioactive materials, and Type B or highway route controlled quantity packages of radioactive materials
The shipper is required to notify the consignee of the dates of shipment and expected arrival. The shipper must also notify each consignee of any special loading/unloading instructions prior to the first shipment.
Shipments of irradiated reactor fuel
The shipper must provide physical protection in compliance with a plan established under either:
Notes: The shipper’s certification on a shipping paper for transportation of hazardous materials requires the shipper to certify that the above-named materials are properly classified, described, packaged, marked and labeled, and are in proper condition for transportation according to the applicable regulations of the DOT.
The shipper, or the person or employee of the person who originates the shipment for transportation is responsible for properly preparing the hazardous material for transportation. The hazardous material must be properly classified to ensure that it is prepared using the proper packaging, marking(s), and label(s). If a company is a shipper of hazardous material, it is responsible to understand the preparation requirements including all applicable packaging related requirements.
Hazardous materials can only be transported in packaging that are authorized by the Hazardous Materials Regulations (HMR). The packaging authorized in Part 173 can only be used for a hazardous material if the section in Part 173 is referenced in Column 8 of the Hazardous Materials Table for the proper shipping name chosen for the material.
Part 173 provides detailed packaging rules for each class of hazardous materials. The packaging requirements set for a specific hazardous material are the same for all modes of transportation unless otherwise stated or exceptions are authorized.
Specification packaging are cylinders, portable tanks, cargo tanks, and tank car tanks for which the Department of Transportation (DOT) has issued detailed manufacturing specifications.
Manufacturers must mark all authorized packagings as required by Parts 178 and 179 of the Hazardous Materials Regulations (HMR). This marking is the manufacturer’s certification that the packaging has been manufactured and tested in accordance with Parts 178 and 179.
At periodic intervals and whenever a company needs to qualify a package design, it must perform drop tests from distances between 2.2 feet and 5.9 feet, as specified in 178.601(e) and 178.603. For other than flat drops, the center of gravity of the test packaging must be vertically over the point of impact.
To periodically test single or composite packagings constructed of stainless steel, nickel, or money, the drop test may be conducted with two samples—one sample each for the two drop orientations. The regulations allow companies to use samples that may have previously been used for the hydrostatic pressure or stacking test.
For details about exceptions for the number of steel and aluminum packaging samples used for conducting the drop test, contact the Pipeline and Hazardous Materials Safety Administration (PHMSA).
Passing the test
A package is considered to successfully pass the drop tests if, for each sample tested:
Using compressed air or other suitable gases, a company must perform a leakproofness test on all packagings intended to contain liquids. The packaging must pass the test — i.e., no air leaks from the packaging — before being used in transportation and before any reuse authorized under 173.28. Normally, three samples of each different packaging must be tested.
For design qualification and periodic testing, packagings must be tested with closures in place. For production testing, however, this is not necessary, and removable heads need not be installed, either. For testing with closures in place, vented closures must either be replaced by similar non-vented closures, or the vent must be sealed.
In testing, the packaging must be restrained under water while an internal air pressure is applied, and the method of restraint must not affect the results of the test. The test must be conducted, for other than production testing, for a minimum time of five minutes. Other methods, at least equally effective, may be used in accordance with Appendix B of Part 178.
An internal air pressure (gauge) must be applied to the packaging as indicated for the following packing groups:
Passing the test
A packaging passes the leakproofness test if there is no leakage of air from the packaging.
At periodic intervals and whenever qualifying a metal, plastic, and composite packaging design type intended to contain liquids, a company must perform the hydrostatic pressure test as specified in 178.601(e) and 178.605, and no leakage can occur. This test is not required, however, for inner packagings of combination packagings. For internal pressure requirements for inner packagings of combination packagings intended for transportation by aircraft, see 173.27(c).
Normally, the regulations require three test samples for each different packaging — although one will suffice for packagings constructed of stainless steel, monel, or nickel. Other exceptions require approval from the Pipeline and Hazardous Materials Safety Administration (PHMSA).
Replace vented closures with similar non-vented closures or seal the vent during the test.
Metal packagings and composite packagings other than plastic (e.g., glass, porcelain or stoneware), including their closures, must be subjected to the test pressure for five minutes. Plastic packagings and composite packagings (plastic material), including their closures, must be subjected to the test pressure for 30 minutes.
This pressure is the one to be marked as required in 178.503(a)(5) of this part. The receptacles must be supported in a manner that does not invalidate the test. The test pressure — as specified in detail in 178.605(d) — must be applied continuously and evenly, and it must be kept constant throughout the test period.
Passing the test
A packaging passes the hydrostatic test if, for each sample, there is no leakage of liquid from the packaging.
All packaging design types, other than bags, must be subjected to a stacking test. The regulations require three test samples for each different packaging — except for one each for periodic retesting stainless steel, monel, or nickel packaging. Exceptions for the number of aluminum and steel sample packagings require approval from the Pipeline and Hazardous Materials Safety Administration (PHMSA). Notwithstanding the provisions of178.602(a) of this subpart, combination packagings may be subjected to the stacking test without their inner packagings, except where this would invalidate the test results.
The test sample must be subjected to a force applied to the top surface of the test sample equivalent to the total weight of identical packages that might be stacked on it during transport. The minimum height of the stack, including the test sample, must be 3.0 m (10 feet). The duration of the test must be 24 hours, except that plastic drums, jerricans, and composite packaging 6HH, intended for liquids, shall be subjected to the stacking test for a period of 28 days at a temperature of not less than 40°C (104°F).
Alternative test methods that yield equivalent results may be used if the Associate Administrator approves. In guided load tests, stacking stability must be assessed after completion of the test by placing two filled packagings of the same type on the test sample. The stacked packages must maintain their position for one hour. Plastic packagings must be cooled to ambient temperature beforehand.
Periodic retesting must take place in accordance with 178.606(c)(1) or using a dynamic compression testing machine that meets the specifications of that section.
Passing the test
No test sample may leak. In composite packagings or combination packagings, there must be no leakage of the filling substance from the inner receptacle, or inner packaging. No test sample may show any deterioration that could adversely affect transportation safety or any distortion likely to:
For the dynamic compression test, a container passes the test if, after application of the required load, there is no buckling of the sidewalls sufficient to cause damage to its expected contents. In no case, may the maximum deflection exceed one inch.
Each packaging must be capable of withstanding, without rupture or leakage, this vibration test procedure:
Other equally effective methods can be used if approved by the Associate Administrator for Hazardous Materials Safety.
Passing the test
A packaging passes the vibration test if there is no rupture or leakage from any of the packages. No test sample should show any deterioration that could adversely affect transportation safety or any distortion liable to reduce packaging strength.
At periodic intervals and whenever a company needs to qualify a package design, it must perform drop tests from distances between 2.2 feet and 5.9 feet, as specified in 178.601(e) and 178.603. For other than flat drops, the center of gravity of the test packaging must be vertically over the point of impact.
To periodically test single or composite packagings constructed of stainless steel, nickel, or money, the drop test may be conducted with two samples—one sample each for the two drop orientations. The regulations allow companies to use samples that may have previously been used for the hydrostatic pressure or stacking test.
For details about exceptions for the number of steel and aluminum packaging samples used for conducting the drop test, contact the Pipeline and Hazardous Materials Safety Administration (PHMSA).
Passing the test
A package is considered to successfully pass the drop tests if, for each sample tested:
Using compressed air or other suitable gases, a company must perform a leakproofness test on all packagings intended to contain liquids. The packaging must pass the test — i.e., no air leaks from the packaging — before being used in transportation and before any reuse authorized under 173.28. Normally, three samples of each different packaging must be tested.
For design qualification and periodic testing, packagings must be tested with closures in place. For production testing, however, this is not necessary, and removable heads need not be installed, either. For testing with closures in place, vented closures must either be replaced by similar non-vented closures, or the vent must be sealed.
In testing, the packaging must be restrained under water while an internal air pressure is applied, and the method of restraint must not affect the results of the test. The test must be conducted, for other than production testing, for a minimum time of five minutes. Other methods, at least equally effective, may be used in accordance with Appendix B of Part 178.
An internal air pressure (gauge) must be applied to the packaging as indicated for the following packing groups:
Passing the test
A packaging passes the leakproofness test if there is no leakage of air from the packaging.
At periodic intervals and whenever qualifying a metal, plastic, and composite packaging design type intended to contain liquids, a company must perform the hydrostatic pressure test as specified in 178.601(e) and 178.605, and no leakage can occur. This test is not required, however, for inner packagings of combination packagings. For internal pressure requirements for inner packagings of combination packagings intended for transportation by aircraft, see 173.27(c).
Normally, the regulations require three test samples for each different packaging — although one will suffice for packagings constructed of stainless steel, monel, or nickel. Other exceptions require approval from the Pipeline and Hazardous Materials Safety Administration (PHMSA).
Replace vented closures with similar non-vented closures or seal the vent during the test.
Metal packagings and composite packagings other than plastic (e.g., glass, porcelain or stoneware), including their closures, must be subjected to the test pressure for five minutes. Plastic packagings and composite packagings (plastic material), including their closures, must be subjected to the test pressure for 30 minutes.
This pressure is the one to be marked as required in 178.503(a)(5) of this part. The receptacles must be supported in a manner that does not invalidate the test. The test pressure — as specified in detail in 178.605(d) — must be applied continuously and evenly, and it must be kept constant throughout the test period.
Passing the test
A packaging passes the hydrostatic test if, for each sample, there is no leakage of liquid from the packaging.
All packaging design types, other than bags, must be subjected to a stacking test. The regulations require three test samples for each different packaging — except for one each for periodic retesting stainless steel, monel, or nickel packaging. Exceptions for the number of aluminum and steel sample packagings require approval from the Pipeline and Hazardous Materials Safety Administration (PHMSA). Notwithstanding the provisions of178.602(a) of this subpart, combination packagings may be subjected to the stacking test without their inner packagings, except where this would invalidate the test results.
The test sample must be subjected to a force applied to the top surface of the test sample equivalent to the total weight of identical packages that might be stacked on it during transport. The minimum height of the stack, including the test sample, must be 3.0 m (10 feet). The duration of the test must be 24 hours, except that plastic drums, jerricans, and composite packaging 6HH, intended for liquids, shall be subjected to the stacking test for a period of 28 days at a temperature of not less than 40°C (104°F).
Alternative test methods that yield equivalent results may be used if the Associate Administrator approves. In guided load tests, stacking stability must be assessed after completion of the test by placing two filled packagings of the same type on the test sample. The stacked packages must maintain their position for one hour. Plastic packagings must be cooled to ambient temperature beforehand.
Periodic retesting must take place in accordance with 178.606(c)(1) or using a dynamic compression testing machine that meets the specifications of that section.
Passing the test
No test sample may leak. In composite packagings or combination packagings, there must be no leakage of the filling substance from the inner receptacle, or inner packaging. No test sample may show any deterioration that could adversely affect transportation safety or any distortion likely to:
For the dynamic compression test, a container passes the test if, after application of the required load, there is no buckling of the sidewalls sufficient to cause damage to its expected contents. In no case, may the maximum deflection exceed one inch.
Each packaging must be capable of withstanding, without rupture or leakage, this vibration test procedure:
Other equally effective methods can be used if approved by the Associate Administrator for Hazardous Materials Safety.
Passing the test
A packaging passes the vibration test if there is no rupture or leakage from any of the packages. No test sample should show any deterioration that could adversely affect transportation safety or any distortion liable to reduce packaging strength.
Unless otherwise specified, in order for a person to offer a hazardous material for transportation in a packaging authorized by an exemption/special permit, the person must be “the holder of” or “party to” the exemption/special permit.
If an exemption/special permit authorizes the use of a packaging for the shipment or transportation of a hazardous material by any person or class of persons other than or in addition to the holder of the exemption/special permit, that person or a member of the specified class of persons may use the packaging for the purposes authorized in the exemption/special permit subject to the terms specified in the exemption/special permit.
Copies of exemption/special permits may be obtained by accessing the Pipeline and Hazardous Materials Safety Administration (PHMSA) website or calling the Office of Hazardous Materials Special Permits and Approvals at (202) 366-4433.
When an exemption/special permit issued to a person who offers a hazardous material contains requirements that apply to a carrier of the hazardous material, the offeror must furnish a copy of the exemption/special permit to the carrier before or at the time a shipment is tendered. Notes: An exemption/special permit is different from an exception.
An exemption/special permit is a statement from PHMSA authorizing a person or persons to use a packaging other than specifically indicated in the Hazardous Materials Regulations (HMR). A company, in most cases, must apply to get, use, or be allowed to use (be a party to) an existing exemption/special permit.
In some cases, an exemption/special permit may be given to an unnamed group or a category of persons meeting certain criteria. This type of exemption/special permit allows broader use but may only be utilized when the involved parties are fully aware of the conditions required in the exemption/special permit and only if a copy of the exemption/special permit is maintained at the location using it.
An exception is a statement of conditions listed in the HMR, that allows any person who meets them to be excepted from certain requirements of the HMR. Meeting the criteria for an exception excepts a company from some or all of the HMR’s requirements. Which requirements are excepted will be specifically indicated in the wording of the exception.
United Nations (UN) or performance-oriented packaging are non-bulk packagings—except cylinders—that have successfully passed applicable performance tests: Drop Test, Leakproofness Test, Hydrostatic Pressure Test, Stacking Test, and the Vibration Standard.
Manufacturers must mark all authorized packagings (specification or performance-oriented) as required by Parts 178 and 179 of the Hazardous Materials Regulations (HMR). This marking is the manufacturer’s certification that the packaging has been manufactured and tested in accordance with Parts 178 and 179.
The United Nations (UN) markings tell the user many things, including what type of packaging it is and to what level of testing it has passed. The marking must be durable, legible, and clearly visible. The marking must include:
Examples:
This is a fiberboard box (4G), tested for Packing Groups II and III (Y), with a maximum mass of 145 kilograms, designed to contain an inner packaging(S), and manufactured in 1983 (83). It was manufactured in the United States (USA) by a manufacturer whose registered symbol is “RA.”
This is a steel non-removable head drum (1A1) designed as a single package for liquids, tested for Packing Groups II and III (Y) for materials with a specific gravity up to 1.4, hydrostatically tested to 150 kPa, and manufactured in 1983 (83). The drum was manufactured in the United States (USA) by a manufacturer whose registered symbol is “VL824.” The minimum thickness of the material is 1 millimeter.
This marking indicates a steel, non-removable head drum (1A1), designed as a single packaging for liquids, tested for Packing Groups II and III (Y), for materials with a specific gravity of 1.4. It was hydrostatically tested to 150 kPa and was manufactured in 1992 (92). The drum was reconditioned in the United States (USA) by a reconditioner whose registered symbol is “RB” in 1993 (93). The drum was reconditioned (R) and successfully passed the leak proofness test (L).
Any packaging required by the Hazardous Materials Regulations to conform to a UN standard must be marked in a manner such as illustrated above.
United Nations (UN) or performance-oriented packaging are non-bulk packagings—except cylinders—that have successfully passed applicable performance tests: Drop Test, Leakproofness Test, Hydrostatic Pressure Test, Stacking Test, and the Vibration Standard.
Manufacturers must mark all authorized packagings (specification or performance-oriented) as required by Parts 178 and 179 of the Hazardous Materials Regulations (HMR). This marking is the manufacturer’s certification that the packaging has been manufactured and tested in accordance with Parts 178 and179.
The United Nations (UN) markings tell the user many things, including what type of packaging it is and to what level of testing it has passed. The marking must be durable, legible, and clearly visible. The marking must include:
Examples:
This is a fiberboard box (4G), tested for Packing Groups II and III (Y), with a maximum mass of 145 kilograms, designed to contain an inner packaging(S), and manufactured in 1983 (83). It was manufactured in the United States (USA) by a manufacturer whose registered symbol is “RA.”
This is a steel non-removable head drum (1A1) designed as a single package for liquids, tested for Packing Groups II and III (Y) for materials with a specific gravity up to 1.4, hydrostatically tested to 150 kPa, and manufactured in 1983 (83). The drum was manufactured in the United States (USA) by a manufacturer whose registered symbol is “VL824.” The minimum thickness of the material is 1 millimeter.
This marking indicates a steel, non-removable head drum (1A1), designed as a single packaging for liquids, tested for Packing Groups II and III (Y), for materials with a specific gravity of 1.4. It was hydrostatically tested to 150 kPa and was manufactured in 1992 (92). The drum was reconditioned in the United States (USA) by a reconditioner whose registered symbol is “RB” in 1993 (93). The drum was reconditioned (R) and successfully passed the leak proofness test (L).
Any packaging required by the Hazardous Materials Regulations to conform to a UN standard must be marked in a manner such as illustrated above.
The more hazardous the material, the more restrictive the packaging requirements will be. This is not just determined by the hazard class, but also by the degree of hazard, i.e., the packing group.
Example: Not all flammable liquids present the same degree of danger, and the packaging requirements recognize this. The packaging requirements for a Packing Group I, Class 3 (flammable) material (initial boiling point less than or equal to 35°C) are more restrictive than for a Packing Group II, Class 3 material (flashpoint less than 23°C, initial boiling point greater than 35°C).
Packaging test requirements are more or less restrictive depending upon the Packing Group of the material for which the package is to be used.
Example: For a material with a specific gravity £1.2, the drop height for Packing Group I is 1.8 m (5.9 feet), Packing Group II is 1.2 m (3.9 feet) and Packing Group III is 0.8 m (2.6 feet). For a material with a specific gravity >1.2, a formula exists for each packing group that is to be used in determining the drop height.
All packages or packaging (bulk and non-bulk) must comply with the “General requirements for packagings and packages” (173.24), including: new and reused packagings, and specification and non-specification packages, unless excepted. These requirements are in addition to those that Part 178 spells out. In addition, non-bulk packagings and packages must also be in compliance with the requirements of 173.24a “Additional general requirements for non-bulk packagings and packages,” and bulk packagings with the requirements of 173.24b “Additional general requirements for bulk packagings.”
It is the responsibility of the person offering a hazardous material for transportation to ensure that the packagings are compatible with the hazardous material they are used for. This particularly applies to corrosivity, permeability, softening, premature aging, and embrittlement.
Packaging materials and contents must be such that there will be no significant chemical or galvanic reaction between the materials and contents of the package.
Plastic packagings and receptacles
Plastic used in packagings and receptacles must be of a type compatible with the hazardous material the packaging will be used for and may not be permeable to an extent that a hazardous condition is likely to occur during transportation, handling, or refilling.
Each plastic packaging or receptacle which is used for liquid hazardous materials must be capable of withstanding without failure the procedure specified in Appendix B of Part 173 - Procedure for Testing Chemical Compatibility and Rate of Permeation in Plastic Packagings and Receptacles. See Section 173.24(e)(3)(ii) and (iii) for more specific information about required testing results.
Compatibility
Hazardous materials may not be packed or mixed together in the same outer packaging with other hazardous or nonhazardous materials if such materials are capable of reacting dangerously with each other and causing:
Packagings for solids which may change state during transportation
Packagings used for solids, which may become liquid at temperatures likely to be encountered during transportation, must be capable of containing the hazardous material in the liquid state.
Closures
Closures must be designed and closed that under conditions such as changes in temperature, pressure, and vibration which are normally encountered in transportation:
A closure, including gaskets or other closure components, if any, used on a specification packaging must conform to all applicable requirements of the specification, except as otherwise provided in the HMR.
Venting
Venting of packagings, to reduce internal pressure which may develop by the evolution of gas from the contents, is permitted only when:
IBCs may be vented when required and must be of a type that has successfully passed applicable design qualification tests with no release of hazmat.
Outage and filling limits
When filling packagings and receptacles for liquids, sufficient ullage (outage) must be left to ensure that neither leakage nor permanent distortion of the packaging or receptacle will occur as a result of an expansion of the liquid caused by temperatures likely to be encountered during transportation.
Requirements for outage and filling limits for non-bulk and bulk packagings are specified in Section 173.24a(d) and 173.24b(a), respectively.
Filling limits for compressed gases and cryogenic liquids are specified in Section 173.301 through 173.306 for cylinders and 173.314 through 173.319 for bulk packagings.
Air transportation
Packages offered or intended for transportation by aircraft are subject to requirements additional to those of other modes of transport and must conform to the general requirements for transportation by aircraft in 173.27.
Additional information concerning packaging requirements for preparation of hazardous materials are found in other sections of the HMR.
Packagings and receptacles used more than once must be in such condition, including closure devices and cushioning materials, that they conform in all respects to the prescribed requirements of the Hazardous Materials Regulations (HMR). Before reuse, each packaging must be inspected and may not be reused unless free from incompatible residue, rupture, or other damage which reduces its structural integrity.
A non-bulk packaging used more than once must conform to the provisions and limitations detailed in Section 173.28(b).
What is reconditioning?
Reconditioning of metal drums according to the HMR means:
Packagings that have visible pitting, significant reduction in material thickness, metal fatigue, damaged threads or closures, or other significant defects, must be rejected.
Reconditioning of a non-bulk packaging other than a metal drum is restoring the packaging by repair or replacement of non-integral packaging components (such as removable gaskets, closure devices, cushioning material, etc.) to a condition such that it conforms in all respects with the prescribed requirements of the HMR.
For a United Nations (UN) 1H1 plastic drum, replacing a removable gasket or closure device with a replacement of the same design and material which provides equivalent performance does not constitute reconditioning. Packagings which have significant unrepairable defects may not be reused.
A person who reconditions a packaging manufactured and marked under the provisions of Subpart L of Part 178 of the HMR, must mark that packaging as required by Section 178.503(c) and (d). The marking is the certification of the reconditioner that the packaging conforms to the standard for which it is marked and that all functions performed by the reconditioner which are prescribed by the HMR have been performed in compliance with the HMR.
The markings applied by the reconditioner may be different from those applied by the manufacturer at the time of original manufacture but may not identify a greater performance capability than that for which the original design type had been tested. For example, the reconditioner may mark a drum which was originally marked as 1A1/Y1.8 as 1A1/Y1.2 or 1A1/Z2.0.
What is remanufacturing?
Remanufacturing of non-bulk packagings for the purpose of the HMR, is:
A person who remanufactures a non-bulk packaging to conform to a specification or standard in Part 178 of the HMR is subject to the requirements ofPart 178 of the HMR as a manufacturer.
What does NRC mean?
A packaging marked as NRC (non-reusable container) according to the Department of Transportation (DOT) specification or UN standard requirements in Part 178 of the HMR may be reused for the shipment of any material not required by the HMR to be shipped in a DOT specification or UN standard packaging.
Notes: The requirements for reuse of packagings are very specific. Be sure to include a thorough discussion of these guidelines in all function-specific training if a company reuses, reconditions, or remanufactures packagings.
Specific types of packagings have different requirements for hazardous materials transportation. Hazardous Materials Regulations (HMR) define the terms and requirements for:
Common types of bulk packagings include cargo tanks, portable tanks, intermediate bulk containers (IBCs), and tank cars.
Common types of non-bulk packagings include boxes, drums, barrels, jerricans, pails, bags, composite packagings, and cylinders.
The regulations include maximum capacity, maximum net mass, and water capacity. Empty packaging must conform to certain provisions or be subject to other requirements of the HMR.
A bulk packaging is a packaging in which hazardous materials are loaded with no intermediate form of containment AND has:
Bulk packaging does not include a vessel or barge. Bulk packaging does include transport vehicles and freight containers. Common types of bulk packagings include cargo tanks, portable tanks, intermediate bulk containers (IBCs), and tank cars.
Bulk packaging is a term that is used throughout the Hazardous Materials Regulations. Knowing if a hazmat package is bulk or non-bulk is an essential piece of knowledge when determining what requirements in the regulations apply to the shipment.
A cargo tank is a bulk packaging that is a tank intended primarily for the carriage of liquids or gases. The cargo tank includes appurtenances, reinforcements, fittings, and closures. A cargo tank is not fabricated under a specification for cylinders, intermediate bulk containers, portable tanks, multi-unit tank car tanks, or tank cars.
A cargo tank is permanently attached to or forms a part of a motor vehicle, or is not permanently attached to a motor vehicle but which, by reason of its size, construction or attachment is loaded or unloaded without being removed from the motor vehicle. The definition for cargo tank can be found in 171.8.
Common specification cargo tanks include MC 306, MC 307, MC 312, DOT 406, DOT 407, and DOT 412. The specifications for construction of cargo tanks can be found in Part 178, subpart J of the Hazardous Materials Regulations.
Cargo tanks are required to undergo certain tests and inspections.
Cargo tanks are required to be properly marked and placarded for transport.
A portable tank is a bulk packaging (except a cylinder having a water capacity of 1000 pounds or less) designed primarily to be loaded onto, or on, or temporarily attached to a transport vehicle or ship and equipped with skids, mountings, or accessories to facilitate handling of the tank by mechanical means. It does not include a cargo tank, tank car, multi-unit tank car tank, or trailer carrying 3AX, 3AAX or 3T cylinders. The definition for portable tank can be found in 171.8.
The specifications for construction of portable tanks can be found in Part 178, subpart H of the Hazardous Materials Regulations. Portable tanks include Department of Transportation (DOT) specification portable tanks, intermodal (IM) portable tanks and United Nations (UN) portable tanks.
Portable tanks are required to undergo certain tests and inspections. For more information see 178.276,178.277, and Part 180, subpart G.
Portable tanks are required to be properly marked, labeled or placarded for transport. For information on these topics see the ezExplanations Markings, Labeling, and Placarding.
An intermediate bulk container (IBC) is a rigid or flexible portable packaging, other than a cylinder or portable tank, which is designed for mechanical handling. The definition for intermediate bulk container can be found in 171.8.
The specifications for construction of intermediate bulk containers can be found in Part 178,subparts N and O of the Hazardous Materials Regulations.
Intermediate bulk containers are required to undergo certain tests and inspections. For more information see Part 180, subpart D.
Intermediate bulk containers are required to be properly marked, labeled or placarded for transport. For information on these topics see the ezExplanations Markings, Labeling, and Placarding.
A non-bulk packaging is a packaging which has:
The definition for non-bulk packaging can be found in 171.8.
Common types of non-bulk packagings include boxes, drums, barrels, jerricans, pails, bags, composite packagings, and cylinders.
Non-bulk packagings that meet the manufacturing requirements in the regulations must be marked with the appropriate United Nations (UN) marking specified in 178.503 or for cylinders the markings specified in Part 178, subpart C.
Non-bulk packaging is a term that is used throughout the Hazardous Materials Regulations. Knowing if a hazmat package is bulk or non-bulk is an essential piece of knowledge when determining what requirements in the regulations apply to the shipment.
The following design requirements apply to non-bulk packages, except as provided for liquid hazardous materials in non-bulk packagings, as detailed in Section 172.312.
A single or composite non-bulk packaging may be filled with a liquid hazardous material only when the specific gravity of the material does not exceed that marked on the packaging, or a specific gravity of 1.2 if not marked, with the following exceptions:
A non-bulk packaging may not be filled with a hazardous material to a gross mass greater than the maximum gross mass marked on the packaging, unless otherwise allowed in Section 173.24a.
Packagings tested with hydrostatic test pressure as prescribed in Section 178.605.
Packagings tested as prescribed in Section 178.503(a)(5) of the Hazardous Materials Regulations (HMR) may be used for liquids only when the vapor pressure of the liquid conforms to one of the following:
No hazardous material may remain on the outside of a package after filling.
An outer non-bulk packaging may contain more than one hazardous material only when:
A packaging containing inner packagings of Division 6.2 materials may not contain other hazardous materials, except dry ice.
Liquids must not completely fill a receptacle at a temperature of 55 degrees C (131 degrees F) or less.
A cylinder is a pressure vessel designed for pressure higher than 40 psia (pounds per square inch absolute) and has a circular cross section. It does not include a portable tank, multi-unit tank car tank, tank car, or cargo tank. The definition for cylinder can be found in 171.8.
The specifications for construction of cylinders can be found in Part 178, subpart C of the Hazardous Materials Regulations (HMR).
Cylinders are required to undergo certain tests and inspections. For more information see Part 180, subpart C.
Cylinders are required to be properly marked and labeled for transport. Placards may be required for transporting certain loads of cylinders.
What is an overpack? According to the definition in Section 171.8:
An 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, except as provided in Subpart K of Part 178. An overpack does not include a transport vehicle, freight container, or aircraft unit load device.
Examples of overpacks are one or more packages:
Authorized packages containing hazardous materials may be offered for transportation in an overpack as defined in Section 171.8 of the Hazardous Materials Regulations (HMR), if all of the following conditions are met:
Shrink-wrapped or stretch-wrapped trays may be used as outer packagings for inner packagings prepared in accordance with the limited quantity provisions or consumer commodity provisions of the HMR, provided that the inner packagings are not fragile, liable to break or be easily punctured. Each package may not exceed 20 kg (44 lbs) gross weight.
Hazardous materials which are required to be labeled “POISON” may be transported in the same motor vehicle with material that is marked or known to be foodstuffs, feed or any edible material intended for consumption by humans or animals provided the hazardous materials:
Notes: An overpack is generally thought of as being an outer enclosure containing a package or packages. Authorized overpacks for use in combination packagings will be discussed in more detail in the topic: Hazmat - Non-bulk Packagings.
A non-bulk packaging is a packaging which has:
The definition for non-bulk packaging can be found in 171.8.
Common types of non-bulk packagings include boxes, drums, barrels, jerricans, pails, bags, composite packagings, and cylinders.
Non-bulk packagings that meet the manufacturing requirements in the regulations must be marked with the appropriate United Nations (UN) marking specified in 178.503 or for cylinders the markings specified in Part 178, Subpart C.
Non-bulk packaging is a term that is used throughout the Hazardous Materials Regulations. Knowing if a hazmat package is bulk or non-bulk is an essential piece of knowledge when determining what requirements in the regulations apply to the shipment.
An empty packaging containing only the residue of a hazardous material must be offered for transportation and transported in the same manner as when it previously contained a greater quantity of that hazardous material, unless otherwise provided in Section 173.29.
An empty packaging is not subject to any other requirements of the Hazardous Materials Regulations (HMR) if it conforms to the following provisions:
A non-bulk packaging containing only the residue of a hazardous material covered by Table 2 of Section 172.504 of the HMR:
Provisions for describing an empty packaging on a shipping paper are detailed in Section 172.203(e). A package which contains a residue of an elevated temperature material may remain marked in the same manner as when it contained a greater quantity of the materials even though it no longer meets the definition in Section 171.8 for an elevated temperature material.
Note: It is important to note that unless all traces of the hazardous material have been removed, the packaging still possesses the hazard of that material and as such still poses a risk in transportation.
Specific types of packagings have different requirements for hazardous materials transportation. Hazardous Materials Regulations (HMR) define the terms and requirements for:
Common types of bulk packagings include cargo tanks, portable tanks, intermediate bulk containers (IBCs), and tank cars.
Common types of non-bulk packagings include boxes, drums, barrels, jerricans, pails, bags, composite packagings, and cylinders.
The regulations include maximum capacity, maximum net mass, and water capacity. Empty packaging must conform to certain provisions or be subject to other requirements of the HMR.
A bulk packaging is a packaging in which hazardous materials are loaded with no intermediate form of containment AND has:
Bulk packaging does not include a vessel or barge. Bulk packaging does include transport vehicles and freight containers. Common types of bulk packagings include cargo tanks, portable tanks, intermediate bulk containers (IBCs), and tank cars.
Bulk packaging is a term that is used throughout the Hazardous Materials Regulations. Knowing if a hazmat package is bulk or non-bulk is an essential piece of knowledge when determining what requirements in the regulations apply to the shipment.
A cargo tank is a bulk packaging that is a tank intended primarily for the carriage of liquids or gases. The cargo tank includes appurtenances, reinforcements, fittings, and closures. A cargo tank is not fabricated under a specification for cylinders, intermediate bulk containers, portable tanks, multi-unit tank car tanks, or tank cars.
A cargo tank is permanently attached to or forms a part of a motor vehicle, or is not permanently attached to a motor vehicle but which, by reason of its size, construction or attachment is loaded or unloaded without being removed from the motor vehicle. The definition for cargo tank can be found in 171.8.
Common specification cargo tanks include MC 306, MC 307, MC 312, DOT 406, DOT 407, and DOT 412. The specifications for construction of cargo tanks can be found in Part 178, subpart J of the Hazardous Materials Regulations.
Cargo tanks are required to undergo certain tests and inspections.
Cargo tanks are required to be properly marked and placarded for transport.
A portable tank is a bulk packaging (except a cylinder having a water capacity of 1000 pounds or less) designed primarily to be loaded onto, or on, or temporarily attached to a transport vehicle or ship and equipped with skids, mountings, or accessories to facilitate handling of the tank by mechanical means. It does not include a cargo tank, tank car, multi-unit tank car tank, or trailer carrying 3AX, 3AAX or 3T cylinders. The definition for portable tank can be found in 171.8.
The specifications for construction of portable tanks can be found in Part 178, subpart H of the Hazardous Materials Regulations. Portable tanks include Department of Transportation (DOT) specification portable tanks, intermodal (IM) portable tanks and United Nations (UN) portable tanks.
Portable tanks are required to undergo certain tests and inspections. For more information see 178.276,178.277, and Part 180, subpart G.
Portable tanks are required to be properly marked, labeled or placarded for transport. For information on these topics see the ezExplanations Markings, Labeling, and Placarding.
An intermediate bulk container (IBC) is a rigid or flexible portable packaging, other than a cylinder or portable tank, which is designed for mechanical handling. The definition for intermediate bulk container can be found in 171.8.
The specifications for construction of intermediate bulk containers can be found in Part 178,subparts N and O of the Hazardous Materials Regulations.
Intermediate bulk containers are required to undergo certain tests and inspections. For more information see Part 180, subpart D.
Intermediate bulk containers are required to be properly marked, labeled or placarded for transport. For information on these topics see the ezExplanations Markings, Labeling, and Placarding.
A cargo tank is a bulk packaging that is a tank intended primarily for the carriage of liquids or gases. The cargo tank includes appurtenances, reinforcements, fittings, and closures. A cargo tank is not fabricated under a specification for cylinders, intermediate bulk containers, portable tanks, multi-unit tank car tanks, or tank cars.
A cargo tank is permanently attached to or forms a part of a motor vehicle, or is not permanently attached to a motor vehicle but which, by reason of its size, construction or attachment is loaded or unloaded without being removed from the motor vehicle. The definition for cargo tank can be found in 171.8.
Common specification cargo tanks include MC 306, MC 307, MC 312, DOT 406, DOT 407, and DOT 412. The specifications for construction of cargo tanks can be found in Part 178, subpart J of the Hazardous Materials Regulations.
Cargo tanks are required to undergo certain tests and inspections.
Cargo tanks are required to be properly marked and placarded for transport.
A portable tank is a bulk packaging (except a cylinder having a water capacity of 1000 pounds or less) designed primarily to be loaded onto, or on, or temporarily attached to a transport vehicle or ship and equipped with skids, mountings, or accessories to facilitate handling of the tank by mechanical means. It does not include a cargo tank, tank car, multi-unit tank car tank, or trailer carrying 3AX, 3AAX or 3T cylinders. The definition for portable tank can be found in 171.8.
The specifications for construction of portable tanks can be found in Part 178, subpart H of the Hazardous Materials Regulations. Portable tanks include Department of Transportation (DOT) specification portable tanks, intermodal (IM) portable tanks and United Nations (UN) portable tanks.
Portable tanks are required to undergo certain tests and inspections. For more information see 178.276,178.277, and Part 180, subpart G.
Portable tanks are required to be properly marked, labeled or placarded for transport. For information on these topics see the ezExplanations Markings, Labeling, and Placarding.