Packaging Engineers –
New requirements are now in effect for dangerous
goods (hazardous materials) packaging intended for air shipment.
It has always been a requirement that glass or other breakable
inner packagings must have an absorbent material as well as cushioning
for liquids in PG I and PG II.
ICAO and U.S. D.O.T. now require absorbent material for plastic
bottles and metal cans (inner packagings) for packing group I and
II liquids in classes 3, 4, and 8, and divisions 5.1, 5.2, and 6.1
when offered for transport by passenger aircraft and packing group
I materials when offered for cargo aircraft only.
IATA requires absorbent material for PG I & II materials for
passenger and cargo aircraft as well as “cargo aircraft only”
Furthermore, ICAO, DOT, and IATA also require a leak-proof liner such
as a plastic bag when the outer packaging is not leak-tight (such
as a steel, aluminum or plastic drums).
New Air Eligibility Mark –
It is optional in 2003 – it becomes mandatory 1 January 2004.
The mark certifies that the shipment meets all of the additional
packaging requirements for shipping by air. It will become a mandatory
requirement on 1 January 2004 and it will be required on all UN
Specification packages, limited quantity packages, and consumer
commodity packages that are offered for air transportation. The
mark must be placed adjacent to the PSN & UN/ID Number markings
or after the marking for Limited Quantity when applicable. Overpacks
must also have the mark.
Anyone responsible for designing or testing hazardous materials packagings
or is responsible for marking packages should examine IATA Section
5.0.2 and 49CFR 173.22, 173.24, 173.25, and 173.27.
Buying off-the-shelf UN Specification
Combination Packaging –
As a company that provides corrective packaging for dangerous goods,
the rejected packages that are referred to us frequently are marked
with UN Specifications but the shipper fails to read the instructions
provided by the manufacturer. Those instructions frequently indicate
that specific cushioning and absorbent materials are required and
special tape for closing boxes must be used. Additionally, the seller
provides bottles and/or inner metal cans because the packaging was
tested with those inner packagings but shippers fail to use them.
Other Packaging Problems
that we see with air freight DG shipments –
Positive means of closure for inner packagings – bottles
and metal cans. Friction lids, such as paint cans, must be clipped
or be fitted with a lock-ring device. Screw top closures should be
tightened to the manufacturer’s-suggested torque. Tape should
be used to prevent loosening due to vibration.
Leak-proof liners are rarely provided with fibreboard
boxes containing liquids.
In our house we have a plaque with a touching poem dealing with
“Footprints” as a religious theme.
Footprints in the sand have had stunning effects
in TV commercials dealing with tropical island vacations. Footprints
have played prominent roles in movie plots. And footprints
at crime scenes have played a role in solving violent crimes. But,
footprints on a box containing dangerous goods?
They tell a story too. It means the trucker or warehouse worker
did not provide the diligent care required in handling dangerous
In a round about way this brings us to the subject of drop
tests. For more than a couple of months we had a small-package
delivery service driver back up to our warehouse door, open the
rear door of the truck, climb into the truck, and unload boxes from
the top of his 8 or 9 foot stack of cargo. Of course, being of average
height, he needed a way to reach the boxes on the top of the stack.
Using driver instincts and ingenuity, he would use other packages
on the floor as step stools. You guessed it – they were usually
packages of dangerous goods. Thus, our comments about footprints.
But, it gets better. The boxes that he removed from the top of the
stack were almost always casually thrown to the floor of the truck.
In effect, Al, the driver, was performing his own drop test. Al’s
drop test was usually a 6 or 7 or 8-foot drop. But dangerous goods
shipments by air usually require a 4-foot test and sometimes a 6-foot
test. When we first discovered Al’s private testing we wanted
to sign the delivery receipt with a notation “possible concealed
damage”. Al’s employer would not allow that –
their policy was either sign off with a clean receipt or refuse
the shipment outright. After numerous rejections and complaints
Al was switched to another route. Perhaps you are now on Al’s
Al’s employer provides HAZMAT training every three years
– a 28-minute film.
“A chain is as strong as its weakest
attention to security now being focused on airfreight.
On Sunday, December 29, 2002, Chuck McCutcheon of the Newhouse News
Service reported that the U.S. Government and the airlines have reached
their goals concerning airline baggage security and now will focus
on the airline cargo business. Both on-airport and off-airport cargo
facilities will be coming under increased scrutiny with more inspections.
Employee background checks and safe and secure handling procedures
will get a renewed focus. If you have taken these matters lightly
in the past make a new year’s resolution to get your security
and HAZMAT training records in order.
(HM-232) TITLE: Hazardous Materials: Security Requirements for Offerors
and Transporters of Hazardous Materials.
DOT/RSPA is still working on this set of rules dealing
with security programs and training. Latest guess out of DGAC is late
February before we find out how it will affect us.
DGAC/Pira International 2003 Global
Conference "Global Dangerous Goods Transportation: What's Next"
March 12-14, 2003, in Prague, Czech Republic.
The Dangerous Goods Advisory Council and PIRA International from Great
Britain have teamed up again this year to conduct their annual international
conference in Prague. Click on www.dgac.org
We hope to see you at the conference.