An insightful examination of the tangled relationship between dangerous goods regulations and compliant packaging.

RIPA Reusable Industrial Packaging Association Washington, DC Skolnik Industries Industrial Packaging for Critical Contents Chicago, IL

Hazardous materials packagings have been regulated in the U.S. by both governmental and private organizations since the early 1900s. First by the Bureau of Explosives (BOE); later by the Interstate Commerce Commission; then DOT (1967)

In 1974, the Hazardous Materials Transportation Act consolidated all DOT regulatory authority in the Materials Transportation Bureau. In 1977 RSPA was formed. Today, hazmat regulations are controlled by PHMSAs Office of HazMat Safety

BOE and ICC loosely regulated hazmat packaging (avoid leakage). By 1967, regulatory controls over packaging expanded and specification packaging was created.

Specification packaging was rigid and, at times, almost funny. DOT 15 box (group 2 hazmats)only made from: Southern yellow pine Hemlock NC pine Douglas Fir Larch

Spec packaging testing rules were rather stringent: Tests 3 times per year Test samples retained (one year) Drop (4 ft.) Hydro (20 p.s.i. for 5 minutes) Leakproofness (15 p.s.i. water or soap over seams)

Closure requirements existed, but only for shippers. Sample closure requirement (1985) Closures (a)Adequate to prevent leakage; gaskets required. (b)Closing part (plug, cap, plate, etc.,) must be made of metal as thick as prescribed for head of container….

Federal hazardous materials transportation law directs the Secretary of Transportation to establish regulations for the safe and secure transportation of hazardous materials in commerce…

…and to persons who manufacture or maintain packaging of a component of packaging that is represented, marked, certified or sold as qualified for use in transportation of hazardous material in commerce.

HM Producers HM Packaging Manufacturers HM Shippers Anyone who may participate in other related transport over public right-of- way.

Steel Drums Plastic Drums IBCs Pails All packagings designed to transport HM

National Governments (e.g. DOT; TDG) United Nations (Global Recommendations) IATA and ICAO (air) IMDG (Water) RID (Rail) ADR ( Road)

Skolnik manufactures about 150 different packagings that are UN certified. DOT requires packaging designs to be recertified every 12 months. Skolnik is a self certifier and does its own testing.

Taking you into our Test Lab and focusing on set up and performance of an individual UN Design Type Test.

LOGSA at Tobyhanna Policing Actions

LOGSA Huge percentage of failures for all packaging design types No failure analysis No subsequent action (except a few fines) Publish results on web; no explanation Alternative Design Validation Testing – not useful Does not reflect field performance

Tobyhanna moved from policing to research Tobyhanna test results available on line at DOT.gov

What to do when the DOT calls! 1. Always anticipate an inspection 2. Run a self audit once per quarter 3. Keep copies of all necessary DOT records (e.g. employee training) in one location. Be sure another person knows where the records are kept.

4.Be sure employees can answer basic questions DOT might ask (e.g. have you been trained in this job function). 5.Accompany the DOT inspector as he conducts the inspection. Record key actions on paper. 6.Get the inspectors name.

7.Keep exit briefing form(s). 8.Fix all noted problems. 9.Call your lawyer.

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