A1. A packaging manufacturer or distributor can voluntarily list its UN certified packagings on the Hazardous Materials Information Exchange (HMIX) under the Topic 23, "RSPA International Activities Relating to the Transport of Dangerous Goods," in the category "UN Packagings." --No database program has been initiated for recording UN certifications issued by third party labs.

A2. On a number of occasions, DOT has sent out interesting of general applicability. In addition, HMIX has been used to send out Q&A's. HMIX could be used in the future to disseminate information, with hard copies to those without access to HMIX.

A3. The UN papers are available for review in the public dockets. In addition, the text of U.S. papers, and the titles of papers submitted by other countries, can be accessed on the HMIX under Topic 23, "RSPA International Activities Relating to the Transport of Dangerous Goods." The HMIX is available to third party certifiers, and many trade associations, such as the Hazardous Materials Advisory Council, monitor these papers. U.S. papers for meetings of ICAO and IMO are also available on HMIX.

A4. DOT does not apply any specific quality assurance standards for calibration.

A5. It is not a question of whether a certain document "supersedes" another. It is a question of how a package is to be shipped and by what mode of transportation. For Shipments within or through the United States, compliance, compliance with 49 CFR (HM-181) is required, except as provided in 49 CFR 171.11 and 171.12. To facilitate trade, particularly in Europe, it is recommend that the documentation certify compliance with performance packaging requirements of the IMDG code and/or ICAO Technical Instructions.

A6. The IATA Dangerous Goods Regulations are not recognized by the U.S. DOT.

A7. If you become aware of an instance of non-compliance with the Hazardous Materials Regulations, you should notify the Office of Hazardous Materials Enforcement (OHME) in writing at DHM-40, Research and Special Programs Administration, 400 Seventh St., S.W., Washington, DC 20590, or by phone at (202) 366-4700. You may also transmit the information to OHME on the HMIX or notify one of the Office of Hazardous Materials Enforcement Regional Offices.

A8. Because the UN Recommendations (9.7.2.1) specifically state that, for combination packagings, separate testing is required for liquids and solids.

Q9. continued:
In the case of combination packagings, can be exceeded when filled with higher specific gravity of Packing Group II or III materials?

A9. No, These provisions are for single and composite packagings only.

A10. The maximum gross mass should generally appear as a whole number, except in cases where it must be carried out to a decimal (eg. for a mass less than on kilogram). If the gross mass appears as a whole number, it must be rounded down.

A11. A test report must contain the information specified in paragraph 178.601(k). That is, specific types, dates, locations, packaging specifications, test specifics (drop heights, hydrostatic pressures, etc.), results, and test operators' names or name of person responsible for testing. Beyond that, we do not specify content or format of the test report. However, we stress the importance of complete documentation so that a packaging in transportation can be linked back to specific test report. The test documentation must identify exactly what was tested.

We do not understand the reference to "DI-R-7127." ASTM has been working on guidelines for the preparation of test documentation under ASTM D 4919. DOT participated at the start of development of the standard; however, DOT has been involved in any additional drafts. The UN subcommittee of Experts agreed to minimum requirements for test documentation at a recent session. If those minimum requirements are adopted in the UN Recommendations, we will consider proposing them for adoption into 49 CFR.

A12. The addition of a 1 quart bottle inside the metal can would be covered under original certification, provided the results of the tests would not be adversely affected. The glass bottle is considered incidental to the tested packaging.

A13. Unless the manufacturer can ascertain that the resins are virtually identical, recertification is required.

Q14. continued:

Section 9.6.2/ASTM D4919 There shall be no release of any of the inner packages from the outer packaging, but minor exposure of the inner package which does not permit their withdrawal is acceptable…

Section 6.2/CAN/CGSB-43.150 None of the inner packagings shall be released from the outer packaging. A minor exposure of the inner packaging is acceptable provided that it is not possible to withdraw the inner packaging.

A14. The criteria for passing the drop test for combination packagings is in 49 CFR 178.603 (f) (4). If damage to the outer packaging is likely to adversely affect safety during transport, the packaging fails the test. If the inner packagings are exposed, safety in transport may be adversely affected; the tester must use some judgment and discretion in determining whether a result is passing or failing. The test report should document the rationale for the determination that a test result is a pass or fail.

A15. The UN Recommendation do not contain a vibration test requirement. The U.S. presented a paper to the UN Subcommittee, proposing the addition of a vibration capability standard to chapter 9. The paper was not adopted. However, a reference to vibration was added to the general requirements for packagings in 9.3.1.

A16. A 49 CFR was revised to authorize the use of dynamic compression testing in lieu of a stacking test for the periodic retest of packagings. The issue of dynamic compression testing was introduced at the UN Subcommittee, but was not accepted. The Subcommittee requires additional information regarding the correlation between dynamic and static testing. Until dynamic compression testing is accepted as an alternative to stacking by the UN Subcommittee, the U.S. has no plans to authorize dynamic compression testing for design qualification testing.

A17. As revised in HM-181 and its corrections and amendments, 49 CFR authorizes the use of helium testing and pressure differential testing as alternatives to immersion testing.

A18. After October 1, 1991, any packaging manufactured and marked to a UN standard must by comply with all requirements of HM-181. That means that any UN packaging manufactured after October 1, 1991 is subject to the periodic retesting provisions of 49 CFR 178.601(c), at the specified frequency. UN packagings manufactured prior to the October 1, 1991 effective date of HM-181 must be retested within 12 months or 24 months of that effective date, depending on the type of packaging.

If a packaging is currently being marked with both a DOT specification and a UN standard, the packaging manufacturer must continue to follow the requirements for production testing in accordance with the DOT specification as well as meet all requirements for the UN standard.

A19. The vibration standard in HM-181 is a "capability" requirement. This means that all non-bulk packagings must be capable of withstanding the vibration standard, but actual testing is not mandatory. If past testing or transportation experience indicates that a packaging can withstand vibration, testing need not be performed. The test report or packaging certification should not the rationale behind the determination that a packaging meets the vibration standard.

A20. Yes.

A21. The solution used for testing must have a specific gravity of at least 1.0, or simulate the specific gravity of 1.0, as in Question 20 above.

A22. No.

A23. Shrink and stretch wrap are not acceptable where a strong outside package is required.

A24. No.

A25. If the regulations specify that a UN standard combination packaging is required, the combination packaging must be tested.

A26. Generally, no. A reduced number of samples is authorized only for periodic retesting of stainless steel, nickel, or morel packagings, or if specifically approved by the Associate Administrator for Hazardous Materials Safety.

A27. Yes, unless the shipper can ascertain that all boxes received from the different box makers are virtually identical (i.e., dimensions, bursting strength, basis weight, flute, caliper, closure system, etc.). The shipper then assumes liability for the integrity of the packagings which are certified in this way.

A28. Yes, unless it can be ascertained that the fiberboard stock is virtually identical and meets criteria which has been established for a board used in a box which successfully passed the required performance standards for a particular specification. For example; if the different suppliers are supplying fiberboard that is virtually identical (same components, manner of construction, burst strength, Cobb rating, etc.) it would not be necessary to retest.