Complying with hazmat packaging regulations is essential. Well, complying with any kind of hazmat regulations is essential, but this specific set is particularly important because it’s so close to the end of the compliance process. Imagine running a marathon and tripping on your shoelaces before reaching the finish line. Failure to comply is like that, except with potentially more catastrophic consequences than missing first place and skinning your knee.
We made a big fuss about packages once before on this blog, but this time, in true hazmat regulations spirit, we are getting more specific. There are a few different types of packaging out there, and you should know how to deal with all of them for the sake of hazmat packaging compliance. Today, we will focus on strong outer packaging.
Defining “Strong Outer Packaging”
Before we get deep into the actual regulations, we should get you up to speed on the specific definition of “strong outer packing.” Here is how 49 CFR’s Hazardous Materials Regulations (specifically, §171.8) define the term in question:
Strong outer packaging means the outermost enclosure that provides protection against the unintentional release of its contents. It is a packaging that is sturdy, durable, and constructed so that it will retain its contents under normal conditions of transportation.
To summarize: it’s packaging, but strong and outer – or at least, further out than any other packaging that may be present. That should be easy to remember, right? The definition goes on to say that packaging “must meet the general packaging requirements of subpart B of part 173 of this subchapter.” This means that packagings of the “strong outer” variety are subject to §173.24. It is also “subject to §173.27” if it is being used to contain dangerous goods set to be transported by aircraft.
That should be no surprise: all types of packaging must meet those requirements. What makes this one notable is one other part of the definition: strong outer packaging – also known as strong outside containers and strong outside packaging – “need not comply with the specification packaging requirements in part 178 of the subchapter.”
What does this mean? The short version is that you can save a great deal of money. The long version … well, that is in the next section.
Specification Packaging Requirements
First things first: a specification packaging is any type of packaging that must meet “the manufacturing and testing specifications” listed in Parts 178 and 179. Depending on factors like the hazmat being packaged and the mode of transport, they must comply with either a Department of Transportation (DOT) specification or a United Nations (UN) standard.
These hazmat packaging regulations can be quite strict, even in comparison with other kinds of hazmat regulations. As a result, the ones that make the grade can be quite costly for shippers and offerors. You might think, “So what? The ‘specification’ designation must mean that this type of packaging is only reserved for a few specific substances, right?” In fact, the opposite is true: most articles and substances defined as hazardous materials you meet will require a specific type of packaging.
Therefore, we suggest identifying the circumstances in which exceptions can be made. In some of these instances, you can use non-specification packaging as a substitute, provided that it is sturdy enough. Strong outer packaging can come in handy if the option to use is available. Using it instead of specification packaging can also save you money. And who doesn’t like saving money!?
Choosing a Suitable Packaging
Strong outer packaging is great, but you cannot just choose any example you find. You can only know that it is sufficient for the job if 1) the regulations say so, and 2) it met rigorous performance standards. That is where the American Society for Testing Materials (ASTM) steps in. This international organization, back in the 1970s, developed a specific standard for testing the performance of shipping containers and systems. Its name? “Standard Practice for Performance Testing of Shipping Containers and Systems,” or D4169 if you prefer one nice, neat codename.
D4169 consists of 16 tests designed to check how packaging responds to different kinds of shipping environments. If something goes wrong, people can examine the results in a safe and contained environment. This is more convenient than examining the results in say, a flaming crater full of radioactive Gila Monsters. If the packaging passes, it receives a stamp of approval so prestigious that the manufacturer can add that to their marketing campaigns. Oh, and offerors can use it to safely and legally transport hazardous materials that call for “strong outer packaging”. It is a win-win all around.
Learn About Hazmat Packaging Compliance Today
The hazmat packing regulations, whether for strong outer packaging or other types, are extensive and comprehensive. This does not necessarily make them as engrossing a read as your favorite vampire books, or a particularly juicy Twitter thread. However, hazmat employees must understand them and comply with them in their work. Any mistakes may result in incidents that could result in civil penalties – or worse an accident that could possibly have an impact on human lives and our environment.
Hazmat University can provide you with the knowledge you need. We offer hazmat training online, which means you can undergo your training from anywhere with an internet connection 24/7. All of our modal initial/recurrent courses including shipping dangerous goods/hazmat in limited quantities and our lithium battery supplement courses, include the specific requirements to the packaging regulations, are completely up to date and jam-packed with useful facts. Start your hazmat training online today!