[Editor's note: This article was submitted to the United Nationís Committee of Experts on the Transport of Dangerous Goods by an international association involved with air cargo issues. It was submitted in support of their position on dangerous goods packaging in air transportation.]
SAFE-BUT BY WHOSE STANDARD?
THE MOVE TO PERFORMANCE-ORIENTED PACKAGING RAISES SERIOUS QUESTIONS FOR HAZMAT SHIPPERS.
By Roy Marshall and Tom Andel
October 1, 1996 has come and gone. If you handle hazardous materials and don't know the significance of this date, you're probably breaking the law. This was to be the final deadline for converting to performance-oriented packaging (POP). In fact, Docket HM-181H has extended the compliance deadline another three years for certain shippers of hazmat. Nevertheless, on this date we were to have moved into the future, leaving behind our old US packaging specifications for the promise of international harmony and the free flow of goods around the world. However, knowledgeable people from many segments of the transportation industry--including shippers, carriers, packaging manufacturers, packaging testing labs, and emergency response personnel--are concerned. they're worried that packaging based solely on minimum POP standards is failing to survive the real-world distribution environment. Most agree the new standards are allowing lower quality packages to enter the US distribution system. Manufacturers and shippers of hazardous materials must take a critical look at how their companies will deal with these new standards when they purchase packaging to be used in the transportation of hazardous materials.
A brief backgrounder
The advent of modern transportation by rail and highway, along with the invention of more and more hazardous materials, resulted in the development of safe packaging. Drums were used extensively for the transportation of chemicals and petroleum products. Design specifications became a hallmark to ensure that a shipper's product could be handled and transported safely and arrive intact at their customer's facility. Materials and construction methods produced hazmat packagings that had proven their merit in transportation by various modes. Developing a new package was time-consuming, but the process ensured its passing the toughest test: observation in the actual transportation environment.
While the adoption of specification packaging in this country ensured a level of safety, other countries didn't have to accept our standards. In fact as other countries adopted their own specifications for drums and other hazmat packaging, it became evident that without international standards, incompatible regulations would hinder the free flow of hazardous materials between countries. A solution to this incompatibility and, in some cases, to the lack of regulations, came from the United Nations' (UN) Committee of Experts on the Transport of Dangerous Goods. This included the adoption of standards that could be used by all nations which based packaging not so much on design as the ability of a given package to pass performance tests. By passing a series of tests, a package design proved itself acceptable for both international and domestic transportation of hazardous materials. A drum designed to contain liquids would have to pass a drop test, leakproof test, hydrostatic pressure test and a stacking test. The problem is that two very different drums may pass the same POP tests and yet only one may survive a lengthy intermodal journey.
Real world survival
European drums generally have been constructed of thinner metal than their US counterparts. One regulatory official from another country insist thinner walled drums perform better during drop tests than their thicker walled American counterparts due the greater flexibility of the thinner steel. But drums rarely fall from trucks. The bigger challenge in the US is to withstand the rigors of disparate distribution environments.
The Dept. of Transportation (DOT) states in 49 CFR 173.24(b) & (b)(1): "Each package used for the shipment of hazardous materials under this subchapter shall be designed, constructed, maintained, filled, its contents so limited, and closed, so that under conditions normally incident to transportation-(1) Except as otherwise provided in this subchapter, there will be no identifiable...release of hazardous materials to the environment." The problem is that two very different drums may pass the same POP tests and yet only one may survive a lengthy intermodal journey. Many argue that the real problem is not with performance-based standards but with the actual tests that do not, in the opinion of experienced companies, associations, and state agencies, adequately reflect a real-world transportation environment in the US. The distance factor of an average transcontinental shipment multiplies the real world problems of abrasion between drums, vibration, shock, puncture, external corrosion, etc. Current POP tests do not address these problems. US manufacturers and shippers have found that with the adoption of POP standards they could use less material and still pass the UN test, thus saving money by purchasing less expensive packaging. And here lies the problem: lower quality packages are more likely to leak during transportation. US DOT regulations require, regardless of the type of package a shipper selects, that a package containing a hazardous material cannot leak during normal transportation. Haldis Fearn, director of hazardous materials for APL, says we need tests that simulate a real world environment. "The places we're seeing the problems is the chimes (of drums) rubbing together," she adds, suggesting tests be developed to simulate these problems. She also feels testing labs need to take a serious look at the real forces packages are subjected to in the various modes of transportation. Some companies have done just that.
Larry Dull, manager of packaging development for Ciba Geigy, and executive of the Chemical Packaging Committee of the Institute of Packaging Professionals, agrees that current POP tests don't go far enough to simulate real-world distribution. He recommends hazmat shippers use tests based on the actual forces a package bears in different distribution environments. Dull has found that the small-package carrier environment, for example, differs significantly from the less-than-truckload (LTL) carrier and rail carrier environments. "For instance, in the small package carrier environment a package will be subjected to more manual handling, sent down chutes, loaded on conveyor belts and brickloaded inside trucks," he continues. Both his previous employer, Eastman Kodak, and Ciba are studying these distribution environments and writing their own performance tests. The sequence in which the individual steps of a total package handling test are conducted is extremely important. Dull says, "we have discovered that if you conduct drop tests on plastic jugs inside of a 4G fiberboard box, you compress the cap liner and relieve some of the application torque on that cap. When you put it into the vibration test it is possible to spin the cap off the bottle with the right combination of frequency and g-level (force)." "A vibration test is mandatory in any distribution system simulation," he concludes. "An accurate vibration test will vary the frequency, say from 5to 100 hz. If you're shipping via rail, make sure you test for horizontal vibration. You can run every kind of vertical vibration and not simulate the vibration unique to rail transportation. The horizontal vibration particularly affects flexible packaging, e.g., bag-in-box." Another chemical manufacturer has adopted a very simple solution in moving from the tried and tested DOT "17E" specification 55 gallon drums: they build their new UN "1A1" steel drums to the DOT specifications. With good blocking and bracing, they have imported thousands of these drums from Europe with few leakers. Extensive training is not only mandatory for their in-house personnel, but for all who handle their warehousing. But Gene Sopchak, manager of hazardous materials and administration for Panalpina, an international logistics/transportation service organization, isn't optimistic about the state of hazmat knowledge in the shipping community. "We're going to have a lot of problems, especially with the vendors," he says. "Many are still involved with the old types of packaging. Purchasers are asking, if it's hazardous, please package it accordingly. Well, it's not being done. And 70% to 75% of them have not even been trained [to do so]. That's where our problem will be." Many of the problems associated with POP packaging have to do not only with poor knowledge of the regulations, but faulty knowledge. Rex Graves, owner of Viking Packing Specialists, Tulsa, OK, says you can't judge a UN-certified package by its cover. "When you test [for UN certification] you do so with all the inner packaging, as well," he points out. "Some people think they can buy a cardboard box with 4G on it, put a label on it, and it's a performance tested package. That's not true. According to IATA (International Air Transportation Assoc.) regulations, bottles, cans, or any inner container of liquid shipped by air have to meet minimum pressure standards of 13.8 psi because pressure changes when you get in the air. The key is to test certify that the package-packaged in this manner with these packing instructions-will pass all the criteria to be a legal package. Anybody buying a UN box who can't get certification on it is not buying a legal package."
Problems down the road?
You may get away with non-compliance for a while when shipping domestically, but if you have overseas markets, out-of-code shipments will cost you in more ways than one. Martin Castle, chief consultant with UK-based Pira International, helps importers on his side of the Atlantic process shipments from the US. He says many times hazmat shipments are in an illegal state for onward shipment. "US industry is still wedded to the system they had since the turn of the century," he says. "Cargo that arrives out of code must be repacked. If it's a straight-forward chemical that can be easily repacked, that's not a very big problem. But when you get into explosives and some types of dangerous articles like batteries, you can get into some difficulty because they might require very special packaging which is not available here and would have to be manufactured." Paul Rankin, president of NABADA-The Assn. Of Container Reconditioners-says the jury is still out on POP and that it is an on-going experiment that should be watched carefully. "If a shipper can buy the thinnest drum out there...then he'll be our experiment," he says, adding "If price alone is allowed to drive the packaging system, then we're going to have serious problems down the road." Problems down the road is just what some in the emergency response community predicted years ago regarding POP. One state hazmat specialist says they're starting to see POP packages fail in the same environment the old DOT spec packages would have survived. "If price alone is allowed to drive the packaging system, then we're going to have serious problems..."
Still, Martin Castle believes for the average chemicals, if shippers follow the basic rules, compliance needn't be enormously expensive. "If shippers follow the rules they shouldn't have any problems in transport," he maintains. Many in the US transportation and emergency response industries may disagree with Castle. Shippers can follow the new rules and still produce packaging which can't survive the US intermodal transportation system. A compliance manager in the agricultural industry says he sees two extremes: packaging that's overbuilt and packaging built to the minimum POP standards. "Shippers have found they can take out the top cardboard padding or the cardboard dividers and the package will still pass the test," he notes. "But when people cut corners, you have problems." There are real benefits in establishing POP standards for hazmat shippers around the world but transportation environments differ greatly and must be considered in the selection of proper hazmat packaging. Don't leave the decision to your purchasing department, who may look only at the cost saving factor of using less expensive packaging that "passed the test." Those responsible for risk analysis should be involved in the transition to UN packaging./p>
Reprinted with permission, TRANSPORTATION & DISTRIBUTION November 1996 (c) 1996, Penton Publishing Inc., Cleveland, OH
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