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['General Packaging Requirements - Hazmat']
['Hazmat Package Testing']
12/01/2023
Copyright 2023 J. J. Keller & Associate, Inc. For re-use options please contact copyright@jjkeller.com or call 800-558-5011.
Copyright 2023 J. J. Keller & Associate, Inc. For re-use options please contact copyright@jjkeller.com or call 800-558-5011.
...
Scope
Package testing requirements apply to anyone who manufactures or tests specification packages.
Regulatory citations
- 49 CFR 178.603 — Drop test
- 49 CFR 178.604 — Leakproofness test
- 49 CFR 178.605 — Hydrostatic pressure test
- 49 CFR 178.606 — Stacking test
- 49 CFR 178.607 — Cooperage test for bung-type wooden barrels
- 49 CFR 178.608 — Vibration standard
Key definitions
- Package: A packaging plus its contents.
- Packaging: A receptacle and any other components or materials necessary for the receptacle to perform its containment function in conformance with the minimum packing requirements.
- Specification packaging: A packaging conforming to one of the specifications or standards for packagings in the Hazardous Materials Regulations.
Summary of requirements
Drop test. At periodic intervals and whenever you need to qualify a package design, you 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 you 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 RSPA’s office of the Associate Administrator for Hazardous Materials Safety.
Passing the drop test. A package is considered to successfully pass the drop tests if, for each sample tested:
- Receptacles containing liquid, each receptacle does not leak when equilibrium has been reached between the internal and external pressures;
- Removable head drums for solids, the entire contents are retained by an inner packaging (e.g., a plastic bag) even if the closure on the top head of the drum is no longer sift-proof;
- A bag, neither the outermost ply nor an outer packaging exhibits any damage likely to adversely affect safety during transport;
- A composite or combination packaging, there is no damage to the outer packaging likely to adversely affect safety during transport, and there is no leakage of the filling substance from the inner packaging;
- A drum, jerrican or bag, any discharge from a closure is slight and ends immediately after impact with no further leakage; and
- Class 1 materials, no rupture is permitted which would allow spillage of loose explosive substances or articles from the outer packaging.
Leakproofness test. Using compressed air or other suitable gases, you 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 you first use it 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:
- Packing Group I: Not less than 30 kPa (4psi).
- Packing Group II: Not less than 20 kPa (3psi).
- Packing Group III: Not less than 20 kPa (3psi).
Passing the leakproofness test. A packaging passes the leakproofness test if there is no leakage of air from the packaging.
Hydrostatic pressure test. At periodic intervals and whenever qualifying a metal, plastic, and composite packaging design type intended to contain liquids, you 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 RSPA’s Associate Administrator for Hazardous Materials Safety.
You must 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 hydrostatic test. A packaging passes the hydrostatic test if, for each sample, there is no leakage of liquid from the packaging.
Stacking test. All packaging design types, other than bags, must be subjected to a stacking test. The regulations require three test samples for each different packaging — with the exception of one each for periodic retesting stainless steel, monel, or nickel packaging. Exceptions for the number of aluminum and steel sample packagings require approval from RSPA’s Associate Administrator for Hazardous Materials Safety. Notwithstanding the provisions of 178.602(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 stacking 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
- Reduce its strength,
- Cause instability in stacks of packages, or
- Cause damage to inner packagings that would be likely to reduce safety in transportation.
Vibration standard. Each packaging must be capable of withstanding, without rupture or leakage, this vibration test procedure:
- Select three sample packagings at random that are filled and closed as for shipment.
- Place them on a vibrating platform that has a vertical or rotary double-amplitude (peak-to-peak displacement) of one inch.
- Note: The packages should be constrained horizontally to prevent them from falling off the platform, but must be left free to move vertically, bounce and rotate.
- Perform the test for one hour at a frequency that causes the package to be raised from the vibrating platform to such a degree that a piece of material of approximately 1.6 mm (0.063 inch) thickness (such as steel strapping or paperboard) can be passed between the bottom of any package and the platform.
- Immediately after the vibration period, remove each package from the platform, turn it on its side and look for any evidence of leakage.
Other equally effective methods can be used if they have the approval of the Associate Administrator for Hazardous Materials Safety.
Passing the vibration 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.
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