Requirements for Shipping of Hazardous Materials in Plastic Packaging

by Daniel Stoehr

All too often, a shipper of a hazardous material (hazmat) incorrectly assumes that a non-bulk plastic packaging such as a drum (1H) or jerrican (3H) is not suitable to transport their hazmat.

In fact, a drum or jerrican made entirely of plastic may be used for the transport of a variety of hazmat within the U.S. that are subject to the Department of Transportation (DOT) Hazardous Material Regulations (HMR) or in international commerce when subject to the Dangerous Goods Regulations of the International Air Transport Association (IATA) or the International Maritime Organization (IMO).

NOTE: The hazardous material or hazmat in the HMR is referred to as a “dangerous good” in the international regulations of IATA and IMO.

While largely similar in their regulation of plastic packagings, there is one critical difference between the international regulations and those of the DOT: International regulations limit a plastic packagings lifespan to five years from the date of manufacture.

The regulations of the DOT, IATA and IMO agree on the following regarding any packaging (plastic, metal, wooden, fiberboard, etc.) used to ship hazmat:

The packaging must be authorized for use with the specific hazardous material. This authorization can only be determined from the applicable regulations. For example, in the U.S., packaging authorizations are found in column 8 in the DOT hazmat shipping table at 49 CFR 172.101.
The shipper must determine if the packaging meets the general packing requirements, including but not limited to:
- When closed, there is no identifiable (without the use of instruments) release of hazmat to the environment
- No hazmat residue on the outside of the package
- Packaging must be compatible with its contents
- No significant chemical or galvanic reaction will take place between the packaging and its contents
- Package is closed according to manufacturer’s instructions
- For liquids, sufficient ullage or headspace is left to account for expansion

Because of its unique characteristics, a plastic packaging is subject to additional regulatory requirements. It is the responsibility of the shipper of hazmat in a plastic packaging to ensure the plastic used in the manufacture of the packaging is compatible with the hazmat and, while some permeability is expected, the container may not be so permeable that a hazardous condition, such as a release, is likely to occur during transportation. A plastic packaging intended for a liquid hazmat must also be able to pass specified tests of its permeability.

In most cases when shipping a hazmat, the packaging must be designed, manufactured and tested to meet either a DOT specification or a UN standard. As a non-bulk packaging, a plastic drum or jerrican will be subject to the UN standard. The regulations of the DOT, IATA and IMO contain more stringent requirements for plastic drums and jerricans in order to meet the UN standard. These requirements include:

Packaging must be manufactured from suitable plastic material and be of adequate strength in relation to its capacity and intended use
No used or recycled material may be used in its manufacture except under specific conditions or if given approval by the respective agency (DOT, IATA or IMO)
Carbon black or other suitable pigment or inhibitor may be added if protection from ultra-violet radiation is necessary
Additives are allowed for purposes other than ultra-violet protection if the chemical and physical properties of the packaging are not adversely affected
Wall thickness at every point of the packaging must be appropriate to its capacity and its intended use
The size of openings for filling, emptying and venting in the bodies or heads of non-removable head drums (1H1) and jerricans (3H1) must not exceed specified limits
Closure devices for removable head drums (1H2) and jerricans (3H2) must remain secure and leakproof under normal conditions of transport
Maximum capacity of plastic drums (1H1 & 1H2): 450 L (119 gallons)
Maximum capacity of plastic jerricans (3H1 & 3H2): 60 L (16 gallons)
Maximum net mass of plastic drums (1H1 & 1H2): 400 kg (882 pounds)
Maximum net mass of jerricans (3H1 & 3H2): 120 kg (265 pounds)

A packaging must be marked to indicate which UN standard it is manufactured and tested to meet. While all UN standard packagings must be marked to indicate the year of their manufacture, the regulations applicable to plastic drums or jerricans require them to also be marked with the month of manufacture. It is here that the regulations of IATA and IMO include a critical difference from those of the DOT.

Both the IATA Dangerous Goods Regulations and IMO Dangerous Goods Code limit the term of use for a plastic drum or jerrican (also a rigid plastic IBC and composite IBC with plastic inner receptacles) to no more than five years from the date of manufacture, which amplifies the need to mark the packaging with both the year and month of its manufacture. However, though the DOT regulations also require the month of manufacture mark, there is no limit on the term of use for a plastic drum or jerrican or any other type of packaging within the DOT HMR.

This small but critical difference between the respective regulations has led to much confusion for hazmat shippers. The confusion is increased because the HMR lacks a clear statement that a five-year term limit does not apply to its plastic packaging. The reference to the five-year-term limit for certain plastic packagings that is found in the IATA Dangerous Goods Regulations and the IMO Dangerous Goods Code doesn’t exist in the DOT HMR.

Though a clear citation in the HMR is lacking, the following letters of interpretation clarify the DOT’s position on limits on the term of use for a packaging:

“Non-bulk specification packagings do not ‘expire’” [LOI 99-0246]
“A shipper may purchase a UN packaging, store it indefinitely and then use it without any testing requirements” [LOI 97-0002]

There are many types of packagings available for the transport of hazardous materials within the U.S. and globally. Perhaps you can save money by using a plastic drum or jerrican for your next shipment of hazmat if it is permissible in the HMR. Keep in mind, the responsibility to classify a hazardous material; determine its authorized packaging; apply the correct labels, markings and placards; and complete and sign the shipping paper are the responsibility of the shipper. Refer to the applicable regulations to ensure you ship your hazmat safely.

TAGS: Hazardous Materials

Daniel Stoehr

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