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Where is DOT’s Packaging Testing Program Headed – Including Testing of IBCs

By Earl V. Lind, Senior Technical Advisor    July, 2007

The Industrial Packaging Alliance of North America held its Spring Meeting in Phoenix, AZ on May 2 through 4, 2007. In this article, Mr. Lind outlines the key points of the meeting as they relate to package testing and IBC’s. He strongly focuses on the statements of Nelson A. Lima, Packaging Program Manager for PHMSA, in which he summarizes testing being carried out by the U.S. Army’s Logistics Support Agency (Tobyhanna) as part of PHMSA’s compliance testing program as well as a proposed study on IBCs. One poignant topic of this report is the acknowledgement of extremely high failure rates for various packagings, which may lead PHMSA to standardize testing procedures.

 


 

 

The Industrial Packaging Alliance of North America (IPANA) held its Spring Meeting at the Pointe Hilton at Tapatio Cliffs, Phoenix, AZ on May 2 through 4, 2007. Nelson A. (Anthony) Lima, Packaging Program Manager for the Pipeline and Hazardous Materials Safety Administration’ s (PHMSA) Office of Hazardous Materials Enforcement OHME, gave a presentation at the meeting. In it, he first summarized testing being carried out by the U.S. Army’s Logistics Support Agency (LOGSA), Tobyhanna, PA since 1996, as part of PHMSA’s compliance testing program. A second part of his presentation dealt with a proposed study on IBCs.

Mr. Lima said that since 1996 510 various packaging designs have been tested at Tobyhanna. These included all types of Hazardous Materials packagings from single packagings to combination packagings and IBCs. He pointed out that the failure rate during these tests was 85%. The packagings tested were obtained directly from manufacturers and other sources such as distributors and fillers. He stated that in the future the DOT would be buying more directly from manufacturers.

He observed that the high failure rate at Tobyhanna was not seen as being indicative of U.S. manufacturing quality or indicative of a general situation directly related to incidents in transportation. In part the high failure rate was due to the Department’s focus on testing the high-end packing group rated packagings, the so-called “Macho Marked” packagings, e.g. X 1.9 / 300 which designates a packaging tested for Packing Group I hazardous materials, the most dangerous group, at a specific gravity of 1.9 kg / m3 and 300 kPa hydrostatic test pressure. An X 1.9 rating requires a drop test of 2.7 meters (8.8 feet) when the test liquid is water or antifreeze (glycol) solution. Mr. Lima also stated that the failure rate on reconditioned drums was 100%. He did point out that the HMR do not extensively get into specific industrial standards for test methods. He noted that Tobyhanna followed ASTM D 4919, Standard Guide for Testing of Hazardous Materials Packagings, and used strict pass/fail criteria. Enforcement penalties (fines) based on the test results considered unacceptable have been assessed, however.

PHMSA is looking to standardized testing procedures possibly based on ISO 16104, Packaging — Transport Packaging for Dangerous Goods – Test Methods. PHMSA also has developed a test report template and may make something like it mandatory in the future. Copies of the sample test reports may be found on the DOT website: http://hazmat.dot.gov/
enforce/forms/ohmforms.htm in the section entitled UN Third Party Documents. There are samples for all UN Performance Oriented Packaging (POP) test packagings, except IBCs, including the inner containers of combination packagings. These are in Microsoft Word Document format and contain DOT-suggested information that is required to describe fully the tested packagings as well as the testing and its result. Also see HAZMAT Packager & Shipper’s presentation on test report formats in the July/August 2006 issue, p. 21.

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