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Pack-AdviceSM

5-Steps to Achieving UN/DOT Package Certification
By: DDL Package Engineer Dick Strand and COO Patrick J. Nolan

If you or your company is engaged in the transportation of hazardous material you are obligated to comply with the requirements set forth in the Hazardous Material Regulations (HMR) published by the Department of Transportation (DOT), Title 49 CFR. These regulations include information on package classification, markings, labeling, documentation, specifications, testing procedures and training requirements for your personnel, and conform to the principles established by the United Nations (UN) Model Regulations, Thirteenth Edition.

One way to certify your package for use in the transportation of hazardous material is to submit your package to a DOT approved Third Party Agent (TPA) that is authorized to perform the required test procedures. Pre-approved shipping containers are available from a number of suppliers and offer the shipper a convenient alternative solution. Self-certification is another option for some organizations.

This article presents a 5-Step guide to completing the certification process using a TPA and remaining compliant thereafter.

Step 1 - Applying to a Third Party Agent for Certification
The process begins by submitting a package to an authorized TPA, along with a description of the packaging, drawings and material specifications. This information is required before testing can begin and is available from the manufacturers of the packaging materials. The specifications are used to prepare a detailed inventory of the package. A copy of the Material Safety Data Sheet (MSDS) must be provided. The Applicant is required to submit the total number of complete package assemblies needed for performance testing. The number depends on the type of package and certification requirements and will be discussed during the initial contact.

For example, a 4G-combination package requires eleven complete packages for testing. The packages are prepared as they would be for normal shipment. Primary inners containing liquid are typically filled with water. The 4G example is used throughout this presentation because it is the most common package-type certified.

Step 2 - Audit Process & Package Preparation
The TPA prepares a test report for each certification. This report must contain a description of all packaging with applicable measurements and characteristics. This data determines the type of conditioning and the severity level requirements for testing. During the audit process the TPA validates all packaging specifications and takes actual measurements. This data is compiled into an Audit Summary for the test report.

Combination packages are acclimated to ambient conditions, 73ºF (23ºC) & 50% R.H. for 24 hours prior to testing. Primary inner packages (i.e. bottles) made of plastic are conditioned to 0ºF (-18ºC) for 24 hours prior to testing.

Step 3 - Testing Process
The following tests are performed on a 4G-combination package. The Packing Group and relative density of the actual filler determines performance levels.

Cobb Water Absorption Test - This test is performed on 5-inch square corrugated samples taken from five of the test packages. These are soaked in water for 30-minutes. The five samples are weighed before and after soaking. The delta weight cannot exceed 1.55 grams for each sample.

Drop Test - Five complete packages are dropped from the required drop height; each sample is dropped once, in one of five different orientations. Drop height is determined by the assigned Packing Group and the relative density of the filler used.

Stacking Test - This test is performed on three complete packages by loading each box with a weight equivalent to a 3-meter stack of identically filled packages. This load is determined from a formula specified in the regulations.

The test can be performed with or without the primary inner packaging, but the selected condition must be clearly stated in the test report. The test duration is 24 hours per sample. It is important to emphasize that the load is to be applied to individual packages and not simultaneously to all three.

After the stacking test a stackability test is performed on the same three packages. In this test, two fully packed containers are placed on top of each package used in the stacking test. Test duration is one hour.

Vibration Test - This test is performed on three complete packages and requires the operator to determine the acceleration needed to cause the package to leave the surface of the shaker table. This is accomplished by increasing frequency of the shaker table until the package separates enough to allow a 1/16-inch shim to slide between the package and the table surface. Once the test frequency is determined, the test continues for one hour. Reference: 49 CFR §178.608. UN Regulations do not require vibration testing at this time.

Step 4 - Further Testing
Depending on the transportation mode, further tests may be required. This can include;

Hydrostatic Pressure/Vacuum Test - This test is only required for inner packages that contain liquid and will be shipped by air. The test is performed on three primary inner packages by subjecting the containers to the required pressure for a specified time period.

ISTA Test - Procedure 1A of this regulation specifies drop and vibration tests to be performed on three complete package designs. A ten-drop sequence is performed on each package followed by a loose load vibration test. This test is only required if the Applicant intends to ship via United Parcel Service (UPS).

Step 5 - Certification & Test Report
Upon successful completion of all required tests the TPA will issue a certificate of compliance, which allows the Applicant to apply the appropriate UN markings to the tested package design. The marking may look like this;

This certifies a 4G-type package for Packing Group II products, having a gross mass not exceeding 9.1 kg. The "S" denotes it is either a solid or a combination package and 04 is the date of manufacture (2004) of the outer package. The +AJ is the TPA's identification symbol (+AJ is specific to DDL). Additional markings may be required such as placards, UN identification numbers, and labels.

The test report is prepared after testing and must include specific elements such as the name and address of the TPA and the Applicant, a unique ID, date, manufacturer of the package, audit information, maximum capacity, sample characteristics, test description and results and it must be signed with the name and title of the signatory. Reports are enhanced by the use of color photos and drawings. Typically only an electronic copy of the final test report is provided, while the original remains on file.

In closing, this 5-Step process summarizes a very complex package certification procedure. Once completed and a certificate is issued, the package remains in compliance with UN/DOT standards for one to two years, depending on actual package type. Retesting before the end of the certification period is required if the package design remains in use. As a courtesy, some TPA's mail out reminders to retest, however, it remains the Applicant's responsibility to make sure their package is certified while in use.

About DDL, Inc.
DDL Inc. (www.testedandproven.com) is a full service laboratory with locations in Eden Prairie, Minnesota and Costa Mesa, California. DDL is ISO certified and a DOT approved Third Party Agent authorized to perform test procedures essential to certify packages for use in the transport of hazardous material or dangerous goods.

 

10200 Valley View Road, Suite 101
Eden Prairie, Minnesota 55344
tel: 952.941.9226     fax: 952.941.9318     1.800.229.4235
  3303 Harbor Boulevard, Suite B9
Costa Mesa, California 92626
tel: 714.979.1712     fax: 714.979.1721

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