March 4,2021: Understanding the Way 49 CFR Describes Packagings

The basic unit of hazardous material transportation is the package. The rules for marking, labeling, documenting, loading, unloading, and handling shipments of hazmat during transport are all based around “the package”.   But just what exactly is a package?

As defined at 49 CFR 171.8, a package is the combination of a packaging, and its contents. The packaging being the “…receptacle and other components or materials necessary to safely contain hazardous material during transportation.” By “other components or materials” we mean things like the packing peanuts and tape keeping a box balanced and closed, or the gaskets and valves securing a drum or cylinder closed. Altogether, this means that the package offered for transportation is: some hazardous material, contained inside something, that is filled and closed in a manner suitable for transportation.  For example, an empty box and some packing tape is a packaging, but when you place a bottle of sulfuric acid inside that box and tape it shut, then you have a package.

Authorized Packagings

There are many kinds of packagings, in many shapes and sizes, constructed of different materials; each having to meet certain requirements before being authorized for transportation.  What does it mean to be authorized for transportation?

 Per 49 CFR 173.24(c)(1), a package is authorized for transportation if, and only if, the hazmat is packaged inside a packaging that is prescribed or permitted for that hazmat by an applicable packing instruction or regulatory exception, and that packaging meets the requirements of its design specification or performance standards. This means, you can only pack hazmat inside of containers that are explicitly identified by regulation as suitable for that hazmat, and you must fill, close, and otherwise handle that packaging/package per the terms of the applicable packing instructions, special provisions, and  applicable exclusions. Typically, the packagings authorized for a particular hazardous material are identified in the packing instruction(s) in 49 CFR Part 173, as referenced by column 8 of the Hazmat Table at 49 CFR 172.101.

Every package authorized for transportation must be able to withstand the rigors of transportation by meeting the general requirements of 49 CFR Part 173 Subpart B. These general requirements include things like; don’t leave residue of hazmat on the outside of the packaging, ensure the hazmat is chemically compatible with the material the packaging is made out of, don’t pack different hazmat in the same package if their mixture might create a new hazard, secure all closures in conformance with specifications and/or the manufacturer’s instructions, don’t overfill packages. Some of these can seem obvious, but it all has to be written down in black and white so that everyone is on the same page about acceptable transportation practices.

Specification versus Standard

One way of distinguishing different types of authorized packagings is to look at the difference between specification packagings versus standard or performance-oriented-packaging (POP).  Both specifications and standards are described in 49 CFR Parts 178 and 179. And, both standards and specifications are sets of rules about how packagings must be built before you can fill them with hazmat. The differences are two-fold.

Firstly, specifications are generally used for bulk packagings and cylinders, whereas performance standards are generally used for non-bulk packagings intended to hold liquids or solids.  Secondly, a packaging specification generally describes the procedures for manufacturing the packaging, with or without reference to an industry or international standard. That is the specification that will identify the type of materials to use, the method of assembling the parts together, and other details of design and construction. Sometimes being so specific as to describe the grade of steel or the angle of weld joints.

Unlike specifications, performance standards do not specify the material of construction in great detail (noting steel, other metal, fiberboard, plastic, etc. is sufficient) and are not picky about how the components were assembled. However, under a performance standard, the packaging must pass various tests to prove that it will perform adequately under stress. The tests include things like; dropping the package to see if it bursts, overfilling it and checking for leaks, stacking packages on top of each other and looking for buckling, vibrating the package, and seeing if any of the closures come undone. These tests are all meant to simulate the rigors of transportation. Packages in cargo holds, shipping containers, rail cars, and trucks will experience excessive vibration and extremes of temperature and pressure. And we’ve all seen what bumps and falls can happen during loading & unloading. 

If you’re not manufacturing packagings for hazmat you don’t need to be intimately familiar with all the details of Standards and Specifications in 49 CFR Parts 178 and 179, but it’s important to understand some of the background of where these packagings come from so that you can make informed decisions when selecting packagings for use.

by James Griffin, CDGP

Do you have additional questions about packagings? Does your team need additional training on the safe packaging of hazardous materials? STARS offers both online classes as well as in-person, hands-on training classes.

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