CHAPTER 8 - Learning Unit 2
Packaging

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TABLE OF CONTENTS

[each of the little packages is a link to that item]

Goals and Objectives
Standard (General) Requirements
Exceptions
Small Quantity, Limited Quantity, Waste, Salvage, DOD, Agricultural
Empty Packagings
Forbidden
Performance Oriented Packaging
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Goals and Objectives

Lesson Goal:

Familiarize the student with the Packaging requirements of Title 49 CFR Part 173 for shipments of Hazardous Materials and Waste.

Lesson Objectives:

Upon completion of this lesson:

Given a Hazardous Material or Waste, the student will be able to determine the proper packaging(s) for that material while in transportation, as required by Title 49 CFR.

Recommended Time:

Approximately 1 hour

Materials Required:

Course outline would help. It's on the CD/DVD.

And don't forget you 49 CFR.

Standard:

At the conclusion of this course the accomplishment of the objectives of this lesson will be demonstrated by completing a 25 question written final-term examination, approximately 24% of which will relate to the material covered in this lesson.
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Lesson Conventions
INFORMATION:

When a reference is made to a section of the California Vehicle Code (CVC) it will be highlighted in green: (CVC15210(k))

When a reference is made to a section of Title 49 of the Code of Federal Regulations (CFR) it will be highlighted in blue: (49CFR383.5)

is a symbol that means "Section". 49CFR383.5 means Title 49, Code of Federal Regulations, Section 383.5.

These little packages are a link to what ever is next to it.
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Packaging

ACTION:

In your Student Guide you should be open to Chapter 8 Packaging. We will begin on page 8-8, paragraph III "Standard Requirements". And don't forget to open your 49 CFR. We are going to look in there.

DISCUSSION 1: General Requirements

49 CFR173.24

The Standard Requirements for packaging apply to all Hazardous Materials shipments, whether in bulk or non-bulk packaging. Without going into all the details (read 49 CFR173.24, 24a, and 24b for details) the packaging used for HazMat shipments must be authorized for the product being loaded into it, the packaging shall not react with the HazMat, the packaging shall not leak, the packaging shall not have any residue on the outside of the packaging, and the packaging shall be resistent to damage from normal transportation.

Bottom line, the packaging must keep the HazMat inside the packaging.
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DISCUSSION 2: Exceptions

Small Quantities (49 CFR173.4) and Limited Quantities (49 CFR171.8) are excepted from Specification Packaging but still must meet all other parts of the General Packaging Requirements. They can't leak, react with the contents, and must withstand normal transportation.

Waste material in some Hazard Classes (see 49 CFR173.12(b) for a list) when packaged in combination packagings as a Lab Pack. The inner packages must be all the same Hazard Class. If the inner packages are glass they are limited to 4L each, while metal may be up to 20L each. The outer packaging does not have to be the specification container for that material but must meet the other General Packaging Requirements and be a 1A2, 1B2, 1D, 1G, or 1H2. The gross weight of the package may not exceed 452 pounds (205kg). The Lab Pack my be transported by Highway, Rail, or Cargo Vessel for disposal or recovery only.

There are some Inhalation Hazard and corrosive exceptions, but you will have to read 49 CFR173.12(b) to find out what they are.

Salvage Drums are another exception. These are intended to hold leaking or damaged packages. When used they must meet all the General Packaging Requirements and be 1A2, 1B2, 1N2, or 1H2. They can be no larger than 119 gallons capacity. They must be marked and labeled as any other shipment of Hazardous Material, plus the words "Salvage" or "Salvage Drum". [49 CFR173.3(c)]

The Department of Defense (DOD) must comply with the provisions of 49 CFR unless they use a package they certified as providing equal or greeater strength and efficiency. This includes contract carriers. It can be shipped by any carrier as long as the packaging is not altered or damaged. [49 CFR173.7(a)]

Agricultural Materials are excepted from this Subchapter if it is not Class 2 and in on local roads between fields of the same farm and is in compliance with State statutes. Class 2 materials are only excepted from Part 172, subparts G (emergency info) and H (training).

Any Agricultural Product is excepted fro Part 172, subparts G and H when transported to or from a farm, and within 150 miles of the farm. There are some weight and other requirements. If you are a farmer you might want to check out 49 CFR173.6.

If you have and Exemption (now called "Special Permit") from DOT you may not use the exemption (Special Permit) unless you are a holder or party to the exemption (Special Permit). There must be a copy of the exemption where ever the exempted packaging is used (facility or vehicle). [49 CFR173.22a]
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DISCUSSION 3: Empty Packagings

49 CFR173.29(a)

The basic rule is that empty packagings containing only residue must be offered and transported just as if they full of Hazardous Material (Marking, Labeling, Specification Container, etc).

49 CFR173.29(b)

However, there are some exceptions to that rule (I know that comes as quite a surprise).

Empty packagings (containing only residue) are not subject to this subchapter (that's the entire HMR) if: (applies to bulk and non-bulk)

All of the required HazMat placards, markings and labels are covered, obliterated, or removed and:

The packaging is unused or;

cleaned and purged of vapors or;

refilled with a material that is not hazardous or;

contains only residue of ORM-D, 2.2.

The residue is NOT a Hazardous Waste, Substance, or Marine Pollutant.

This is why gasoline tankers remain placarded and require shipping papers even after they have delivered the loads. They are considered the same as full until they are cleaned and purged of vapors. Actually a really good rule since the vapors are more of a hazard than the liquid.

49 CFR173.29(c)

Non-bulk packagings containing only residue of Table 2 materials (NOT Poison by Inhalation) does not count toward the weight requirements for placarding. Also, it does not require shipping papers if the container is being transported for reconditioning or reuse and transported by private or contract carrier.
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DISCUSSION 4: Forbidden

49 CFR173.21

The first two listed here are just plain forbidden from offering for transport or transporting.

Materials with "Forbidden" in column 3 of the HMT may not be offered or transported.

Explosives forbidden by 173.54 may not be offered or transported.

This next group is forbidden from offering or transporting unless some extra steps are taken.

Electrical devices that may spark or heat may not be offered or transported unless packaged so at to preclude the spark or heat.

Some magnetic material may not be offered or transported by air.

Materials in the same packageing that may mix and cause evolution of heat, toxic vapors, flammable gases, or corrosive material, may not be offered or transported.

Some materials that may decompose or polymerize may not be offered or transported unless certain conditions are met.

Packages that will detonate may not be offered or transported unless classified as an explosive.

Cigarette lighters, ketone peroxides, and oxygen generators also have restrictions on transport.

This is just an overview of the restrictions on transporting some materials. Always review the full section before making decisions about transporting a product or material.
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DISCUSSION 5: Performance Oriented Packaging

49 CFR178.601

We have already discussed much about Performance Oriented Packaging in the first unit of this lesson. But there are a couple items of interest that we need to adress.

First, it is the Manufacturer's responsibility to test the packaging to ensure that it meets the standards established in 49 CFR. When the manufacturer marks the container that is the manufacturer's certification that it can pass the test(s). The container must pass the test(s) before it can be produced. The manufacturer must also notify any customer when it is determined that already delivered containers can't pass the test.

The shipper is responsible for ensuring that closures and assembly meet the standards.
49 CFR178.601(e) & (f) and 49 CFR178.603 through 609 provide some detail on conducting the tests and the standards the container must meet. Again, this is for your information and to give you a feel for what standards the container must meet.
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ACTION:

Now that wasn't too bad, was it? But wait, there's more. Go to the back of Chapter 8 in your student guide (on the CD or the Student Guide button in BlackBoard) and beginning on page 8-A-1 you will find four Practicle Exercises.

In the first one you must identify the authorized containerbased on what is in the exercise question, and identify it by packaging code. Also, indicate the section number where you found the authorization.

The second exercise involves locating and noting where certain packaging information is found.

The third and fourth exercises involve answering some questions about packaging requirments.

You may use your 49 CFR, any notes you have taken, your CD, or you can eMail me if you have questions:

hazmac@dslextreme.com

When you are done with the exercises transcribe the information to the on-line exercises and submit them.They are not scored. It is just a way for me to see how you are doing in the course.

Enjoy yourself and don't stay up too late!
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