A UN Rating Isn’t Enough: Clean Earth Systems Highlights Common Hazardous Materials Packaging Compliance Mistakes

Selecting UN-rated packaging is an important step when preparing regulated hazardous materials for transportation, but the UN marking on a container is only one part of the compliance process.

Clean Earth Systems, Inc., a nationwide provider of hazardous material and waste packaging solutions, is highlighting common packaging mistakes that can create compliance concerns even when a UN-rated drum, pail, box or other container is being used.

Under U.S. Department of Transportation Hazardous Materials Regulations, hazardous materials offered for transportation must be properly classified, described, packaged, marked and labeled as applicable. When UN standard packaging is required, shippers also have responsibilities related to selecting, assembling and closing that packaging correctly.

“Customers sometimes assume that if a container has a UN marking, the compliance piece is taken care of,” said Cory Stiger of Clean Earth Systems. “But the right container still has to be selected for the specific material and used the way it was designed and tested to be used.”

Common Packaging Mistakes Can Be Easy to Overlook

Hazardous materials packaging requirements can vary based on the material being shipped, its classification, packing group, quantity and mode of transportation. As a result, a container that is appropriate for one material or shipment may not necessarily be appropriate for another.

Some areas businesses should pay particular attention to include:

• Selecting packaging based on the UN mark alone. A UN marking communicates information about the tested packaging design and performance level, but it does not mean the package is appropriate for every hazardous material.
• Overlooking closure instructions. When applicable, UN specification packaging must be closed according to the manufacturer's instructions. This can include specific closure components, procedures and torque requirements. 
• Changing components of a tested packaging design. Substituting components or changing the manner in which a package is assembled can affect whether it remains consistent with the tested design. PHMSA has specifically addressed circumstances in which differences in packaging components can constitute a different packaging design. 
• Assuming a previously used container is automatically ready for reuse. Packaging used more than once must meet applicable reuse requirements and be inspected before reuse; damage or other conditions that reduce structural integrity can make a package unsuitable. 
• Failing to maintain required packaging documentation. When the regulations require UN specification packaging, manufacturer notifications and closure instructions may also be subject to retention requirements. 

These details can be particularly important in operations where employees routinely package different waste streams or where drums and other containers are prepared by multiple team members.

Closure Instructions Deserve Particular Attention

One of the easiest details to overlook is also one of the most important: properly closing the package.

For applicable UN standard packaging, federal regulations require closures—including gaskets and other closure components—to conform to the packaging specification and be closed in accordance with the manufacturer's required information.

That means something as seemingly minor as using an incorrect closure method can matter.

PHMSA has stated that using a closure method other than those allowed by the specified closure instructions can constitute a design change requiring the packaging to be requalified.

“Packaging compliance doesn't stop when the correct drum arrives at the facility,” Stiger said. “Employees need access to the right information and need to understand how that packaging is intended to be assembled and closed. Those details are part of using the package correctly.”

Building Packaging Compliance Into Everyday Operations

For hazardous waste generators, environmental service providers and industrial facilities, packaging compliance is easier to manage when it becomes part of the normal procurement and shipping process rather than a last-minute consideration.

Maintaining appropriate packaging inventory, keeping closure instructions accessible, training employees and reviewing packaging requirements before a shipment is prepared can help reduce avoidable problems.

Working with a packaging supplier familiar with hazardous materials applications can also help businesses identify suitable packaging options and obtain the documentation needed to use those products correctly.

Clean Earth Systems supplies UN-rated steel and poly drums, overpacks, salvage drums, lab-pack containers, pails, boxes and other hazardous material and waste packaging through its nationwide distribution network.

“Our role is to make the packaging side of the process as straightforward as possible,” Stiger said. “Customers have enough to manage. Having the right packaging available, along with the information needed to use it properly, can eliminate one more source of uncertainty.”