Requirements for Shipping of Hazardous Materials in Plastic Packaging

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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

Daniel Stoehr is the owner and sole training provider for Daniels Training Services, a company he began in 2010. He is a trained and knowledgeable EHS professional with more than 25 years of experience with the environmental health and safety regulations at the state and federal level. After graduating with a Bachelor’s of Science for Natural Resource Management and Environmental Law Enforcement from UW-Stevens Point, he was employed for 6 years with a waste disposal company where his job responsibilities included manifesting, handling, and transporting hazardous waste throughout the Midwest. More recently he was employed for 13 years by an environmental consulting firm where he was exposed to a wide range of Federal and State EHS regulations pertaining to hazardous waste management and hazardous material transportation. Dan has provided training nationwide at seminars, onsite events, webinars and conferences to fulfill the USEPA training requirements for Hazardous Waste Personnel and those of the USDOT/PHMSA for hazmat employees. His goal is to answer questions and put tools — and the knowledge to use them — into the hands of EHS professionals through engaging and interactive training.

2 Comments

Jody Smithsays:
06/01/2018 at 1:35 pm Reply
49 CFR 173.28 discusses the reuse, reconditioning and remanufacture of packagings.

Section 7 covers the conditions under which a packaging can be reused and clearly specifies the following: (B) Plastic, provided the packaging is not refilled for reuse on a date more
than five years from the date of manufacture marked on the packaging in accordance with § 178.503(a)(6) of this subchapter;

So is it possible to buy plastic drums more than five years old, fill them with product for the first time and not fall subject to this rule?
- Karensays:
  06/19/2018 at 3:32 pm Reply
  Hi Jody,
  
  If the drum is truly being used for the first time, then this particular conditional provision would not apply. However, that doesn’t necessarily mean that the container is suitable for hazardous material shipments.
  
  Although plastic takes centuries to break down in landfills, it does age–especially when it is stored outdoors or in direct UV light. “Old” plastic becomes brittle and can have a chalky or flakey appearance. When it comes to drums, these and other signs of aging can translate to a container that is much more easily damaged during shipment than a newly manufactured drum would be.
  
  Even if the container still looks good, there may be another hurdle to overcome before considering the container. All shippers need to have a copy of a valid UN test certificate for the container as well as closure instructions for the container [49 CFR 173.22(a)(2)(ii)]. These documents must reflect the year that the container was manufactured. So, for example, if the year is 2018 and the container was manufactured in 2013, you would need the test certificate and closure instructions from 2013, not 2018. Note also that container manufacturers, pursuant to 49 CFR 180, will specify time limits for their packagings (typically five years) because they know that container materials as well as lid and bung gaskets do age over time. Also, some countries specify that containers more than five years old may not be used to transport hazardous materials.
  
  As a shipper of hazardous materials, when you sign a manifest, you are certifying that the container that you are using is appropriate for the shipment. That means that the UN certification is appropriate for the material being shipped and that the container will be able to withstand “conditions normally incident to transportation” [49 CFR 171]. In most cases, the few dollars that might be saved by purchasing or using an older container just aren’t worth the risk of a release of product during transport.
  
  Thank you for an interesting question. Please follow up if you need more information.