By Earl V. Lind, Packaging Advisor    January, 2008

Adopting a general practice to mark DOT specification packagings for the highest packaging performance level allowed in the regulations for any hazardous material, can be a major problem. This problem derives from a general tendency in the shipping community to select “one size fits all” packaging to meet their distribution needs. PHMSA has strengthened its inspection policies and its enforcement. It has determined through the testing of packages that the failure rate on X-Marked packagings has been very high. In this article Mr. Lind explains the history of X-Marking, Packaging assignments in the DOT regulations, how this problem came to be, and why the industry should be concerned.

Adopting a general practice to mark DOT specification packagings for the highest packaging performance level allowed in the regulations for any hazardous material, is a major problem. PHMSA has strengthened its inspection policies and its enforcement, and as a result the failure rate on these packagings has been very high. This article discusses the history of macho marking, the concerns of doing it, and whether or not it is warranted.

History and Summary
When the Performance Oriented Packaging (POP) system was being phased in during the early 1990’s, many packaging manufacturers began marking containers they were producing with high ratings. The customer’s rationale was that if packaging in stock generally bore a marking indicating the highest level of performance, it could be used for any hazardous material. This practice was to be followed even if the DOT regulations did not require that level of performance for the packaged material. It was an attempt by packaging users to standardize inventory believing it would lead to higher efficiencies. DOT’s enforcement arm has been collecting evidence that this approach does not achieve what the users of packaging hoped for.

Because of this situation, the marking of UN Performance Oriented Packagings (POP) with the “X” rating indicating the highest level of performance became controversial shortly after DOT issued the POP rules in Docket HM-181 in December 1990. This rulemaking mandated a change from existing DOT packaging specification construction-based standards to the UN POP system outlined in the UN Recommendations for Transport of Dangerous Goods (“The Orange Book”). Also known as the UN Model Regulation, these POP standards are today being used by national regulatory bodies such as the U.S. Department of Transportation (DOT) as the basis for their hazardous materials transportation regulations.

Packaging Assignments in the DOT Regulations
Regulations based on the Orange Book set forth test criteria used to validate that a given packaging design may be used for the transport of a specific hazardous material. The level of performance needed is determined by the Packing Group (PG) to which the goods are assigned. Packing Group means a product grouping according to the degree of danger presented by the hazardous material. Almost all hazardous materials are assigned to packing groups. PG I indicates the most dangerous materials. PG II connotes a medium level of danger. PG III is reserved for the least dangerous materials. Packagings for the three groups are indicated by the letters X, Y and Z, respectively, which appear on each specification packaging. As one would expect, the tests required for each packing group are most rigorous for the PG I category, less so for PG II and lower again for PG III.

How This Problem Came To Be
When this change to performance-oriented packagings was being phased in, manufacturers began marking packagings with high ratings, primarily at the request of their customers. The rationale was that if the packaging displayed a marking indicating it to be capable of passing the highest level of performance, it could then be used for anything, even if the material to be packed did not require that high a level of performance. In an article appearing in the November / December 1990 issue  of The Chemical Packaging Review (now HAZMAT Packager and Shipper) entitled “Container Markings and Chemical Compatibility: What Does “X” Really Mean,” I discussed the general practice of using the “X” marking. I noted, however, that in 49 CFR paragraph 173.24a (b) Non-bulk packaging filling limits, specific DOT rules provide guidance on the use of “X” marked packagings for less dangerous hazardous materials.

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