Performance-Oriented Hazardous Materials Packaging

The hazardous materials classification and applicable packing instruction determine whether a particular nonbulk performance packaging is permitted. Packing group, material state, quantity and transport mode can affect selection. A familiar UN-marked box or drum is not suitable for every dangerous good. Check the packaging authorization alongside the material's classification before treating the package marking as sufficient evidence for a shipment.

Part 178 Subpart M distinguishes design qualification, periodic retesting and relevant production tests. Applicable tests can address drops, leakproofness, hydrostatic pressure, stacking or other subjects according to the package type. The design qualification represents a defined construction and assembly. A change in an inner receptacle, cushioning, closure or outer package can affect the test basis and needs evaluation under the applicable variation provisions.

Section 178.2 treats the prescribed DOT or UN marking as certification that the relevant requirements and functions have been met. The marking identifies a defined performance scope; it is not a general DOT endorsement of the packaging company. Purchasing personnel should reconcile the mark with the exact design type, test evidence and intended contents. Markings on an unrelated sample or obsolete design cannot establish conformity of the delivered packaging.

Manufacturers and subsequent distributors must provide relevant assembly and closure information, including closure components and procedures needed to reproduce the tested configuration. These instructions can cover gaskets, torque, tape or other critical details. Shippers need the instructions for the packaging actually used. Closing a tested package with an improvised method can defeat its performance even when the outer container bears the correct UN mark.

The packaging manufacturer is primarily responsible for Part 178 conformity, while each person performing a regulated function must perform it correctly. The person offering the material for transport is responsible for functions such as final assembly and closure that it performs. Section 173.22 also addresses packaging selection and related certification. Contracting with a packaging supplier does not automatically transfer the shipper's obligation to prepare the particular shipment correctly.

Retain design identification, test reports, instructions, supplier change information and the material-specific packing decision in linked records. At dispatch, verify the packaging condition, components, contents and closure against that decision. Reuse and reconditioning have their own applicable conditions and should not be assumed from the original mark. A packaging quality system should make the tested construction reproducible throughout purchasing, storage, filling and shipment.