That, however, cannot be a one-size-fits-all solution when it comes to the transport of dangerous goods.
A package or containment of dangerous goods is either in compliance with the requirements of the IATA Dangerous Goods Regulations (which, as a field manual, are in reality applied in lieu of the legal foundation, the ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air) or it isn’t.
A number of common misperceptions and misunderstandings are the main reason why many shipments of Dangerous Goods are not in compliance with applicable requirements.
And here is a fact which may elicit surprise: despite the requirement that most shipments of Dangerous Goods transported by air undergo a stringent acceptance check, this safeguard can only verify the outward compliance of a packaging.
What do the regulations say?
Package (Non-Radioactive Material): The complete product of the packing operation consisting of the packaging and contents prepared for transport.
Packaging (Non-Radioactive Material): One or more receptacles and any other components or materials necessary for the receptacles to perform their containment and other safety functions and to ensure compliance with the minimum packing requirements of these regulations.
While Dangerous Goods are divided into nine classes (some with subclasses called divisions) which indicate the nature of the danger, the degree of danger is exhibited by the so-called packing group, indicated by the roman numeral I, II, or III, where I stands for a high or severe danger, II for a medium danger, and III for a low or minor danger.
One would assume that substances and articles which have not been assigned a packing group are harmless, but nothing could be further from the truth: Explosives in Class 1, Gases in Class 2, radioactive substances in Class 7, as well as self-reactive substances in division 4.1, organic peroxides in division 5.2, and infectious substances in division 6.2 have not been assigned to packing groups for various technical reasons.
Since January 1st, 2015, dangerous goods that are considered articles (such as Lithium batteries or thermometers with mercury) are also not assigned a packing group. What’s it all about?
In simple language, the packing group describes the quality of the packaging and its ability to contain the goods.
A substance in packing group I with a high degree of danger must subsequently be packed in a packaging rated for packing group I.
However, most of those substances and articles that have not been assigned a packing group do require packagings of a certain quality.
The requirement is expressed either within the applicable packing instruction and/or in a special provision applicable to the particular substance or article.
What’s the difference?
The regulations differentiate between three types of packagings:
- Combination packagings (consisting of both inner and outer components, such as glass jars packed with cushioning material in a fibreboard box);
- Single packagings (such as jerricans and drums with non-removable heads intended to contain liquids);
- Composite packagings (such as plastic receptacles with an outer steel drums);
- Overpacks.
It is important to understand that “Overpacks” are not considered a means of packaging, and a considerable number of non-compliant shipments result from such misperception.
Per definition, an Overpack is “an enclosure used by a single shipper to contain one or more packages to form one handling unit for convenience of handling and stowage.
“Dangerous Goods packages contained in the Overpack must be properly packed, marked, labelled and in proper condition as required by the regulations.”
Why is that difference important?
Without a proper understanding of the terms “packing” and “packaging,” shipments of Dangerous Goods will not be in compliance with the regulations.
For example, substances and articles with high and medium degrees of danger (Packing Groups I and II) are not permitted for transport aboard passenger aircraft when contained in single packagings.
If paint UN 1263 has a flashpoint of 23 degrees C or less and/or more, it must be shipped as PG I or II, depending on whether its boiling point is above 35 degrees C (PG II) or less (PG I).
If no more than 5.0 liters of such paint is filled into a plastic jerrican and the jerrican is put into a fibreboard box meeting PG II specifications, it will appear to be a compliant package while in reality it isn’t: A single packaging does not become an inner packaging just because it is contained in a fibreboard box regardless of its specifications. It actually still is a single packaging (the jerrican) in an Overpack (the fibreboard box).
Likewise, a lithium battery is not an inner packaging for the Lithium contained therein, so one would need to put the battery into an inner packaging (such as a PE bag) and assemble the bags within the outer packaging.
Also, a “packaging” must, by definition, be marked and labeled as required by the regulations; and packagings contained in Overpacks must all individually meet the packing, marking, and labeling requirements of the IATA Dangerous Good Regulations.
It’s not that simple
While the regulations usually permit various inner packagings in combination with a large scope of outer packagings for any combination packaging within the applicable Packing Instruction, in reality this is further limited by the packaging test report and the closure instructions provided by the manufacturer of the packaging.
If the test report permits inner packagings made of plastic and glass in an outer fibreboard box, inner packagings made from metal may not be used, despite the fact that the regulations show them as permitted.
As a matter of fact, most manufacturers of United Nations performance-tested packagings clearly indicate that where the shipper uses any other component (including such mundane things as adhesive tape for the closure of fibreboard boxes), the test certificate becomes null and void.
The issue is not helped by that fact that inner packagings do not bear any UN specification mark (the reason for this being that DG acceptance checks mandated in air transport only verify outer or single packagings) and that, while a pressure test is required for air transport, it is not required for surface transport.
Likewise, packing instructions require that “substances be compatible with their packagings”—something which is up to the shipper to prove—and that for inner and single packagings containing liquids, “closures must meet the closure requirements” which call for two independent means of securing closures.
But that’s not all
The air transport sector, unlike other modes of transport, has defined certain environmental parameters that must be considered when packing and shipping dangerous goods.
Included are a temperature range between -40 degrees C (-40 degrees F) and +55 degrees C (+131 degrees F), low pressure environments between 0.25 and 0.75 bar, as well as vibrations in a range from 5 mm amplitude at 7 Hz to 0.05 mm amplitude at 200 Hz.
While these numbers may not seem really impressive, a vibration of 5mm amplitude at 7 Hz translates into a force of 1g acceleration, while a vibration of 0.05mm at 200 Hz means 8g acceleration.
When it comes to UN performance-tested specification packaging, the old saying that “there’s more to it than what meets the eye” is certainly true—but only where all requirements have been meticulously met.
Jens
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