TES Technical Safety - Dangerous Goods Containments
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Usage

1. What´s it about?

The term "usage" is not specified in the provisions.
Our definition is as follows: A user is a company which want to fill and transport an approved packaging with dangerous goods. This could be the consignor, packer, filler, loader or carrier as specified in the provisions.


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2. Where can I find an approved packaging?

All approvals issued by BAM can be found in the Database Dangerous Goods Packagings or in Lists of approvals.

Please note, that you should get in contact with the approval holder and not with the manufacturer if you want to by packagings.


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3. How do I find the correct approved packaging?

Step 1 - Determine the classification of the dangerous substance or dangerous object that is to be carried, the aim being to establish: Procedure:
Step 2 - Determine the transport requirements for the dangerous substance or dangerous object that is to be carried.
Procedure:
Step 3 - Go to the corresponding chapter of Part 6 of the regulations and determine the minimum requirements with regard to the construction, equipment, approval, testing and labelling of the dangerous goods enclosure to be used for the respective dangerous substance, and also determine the individual additional requirements that apply for the specific individual application.
Procedure:
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4. UN-Marking of dangerous goods packagings: A selection criterion?

In order to guard against misunderstandings: No, it doesn’t!

The approval is the permission to produce and label from an assembly line a packaging that is to be used for the carriage of dangerous goods; it is not an approval for the use of such goods:

(ADR/RID Chapter 6.1.3 Marking)

The marking indicates, that the packaging which bears it corresponds to a successfully tested design type, and that it complies with the requirements of this Chapter related to the manufacture, but not to the use of the packaging. In itself, therefore, the mark does not necessarily confirm that the packaging may be used for ANY substance: generally the type of packaging (e.g. steel drum), its maximum capacity and/or mass, and any special requirements are specified for each substance in Table A of Chapter 3.2.

Although these explanations can formally only be found for packagings within the narrower sense, they also apply analogously for IBCs and for large packagings, because the same principle of UN coding is to be applied there as for packagings. The first sentence of Note 3 is also worth repeating here again:

The marking does not always provide full details of the test levels, etc., and these may need to be taken further into account, e.g. by reference to a test certificate, to test reports or to a register of successfully tested packagings.

This makes it completely clear that, to meet one's responsibility in this respect, it is not adequate to simply use an authorized packaging bearing a corresponding UN marking without applying more detailed information. This could lead to a totally unacceptable result with respect to the application of the respective packaging.

If all of the relevant information about the test level or detailed test conditions for the packaging or the IBC are present in the above stated sense, the potential user will err nonetheless if he thinks that he has then complied with all of his obligations under the dangerous goods regulations.
The user must know that a packaging may be only meeting the minimum requirements necessary for obtaining an approval for application. Chapter 4.1 of the RID/ADR titled "Use of packagings, including intermediate bulk containers (IBCs) and large packagings" begins with the following ominous requirement:

4.1.1.1 Dangerous goods shall be packed in good quality packagings, including IBCs and large packagings which shall be strong enough to withstand the shocks and loadings normally encountered during carriage, including trans-shipment between transport units and between transport units and warehouses as well as any removal from a pallet or overpack for subsequent manual or mechanical handling.
Packagings, including IBCs and large packagings, shall be constructed and closed so as to prevent any loss of contents when prepared for transport which might be caused under normal conditions of transport, by vibration, or by changes in temperature, humidity or pressure (resulting from altitude, for example). No dangerous residue shall adhere to the outside of packagings, IBCs and large packagings during carriage. These provisions apply, as appropriate, to new, reused, reconditioned or remanufactured packagings and to new, reused, repaired or remanufactured IBCs, and to new or reused large packagings.

Since there is no definition of what worldwide normal conditions of carriage are, the user is obliged to specify a design of packaging that meets the requirements of his particular application, since only he knows whether the packaging will be going on a long sea voyage into hot and moist tropical climates, or by rail into cold Siberia.
Furthermore, the user should know that during shipment by air there will be a drop in air pressure. Thus, even in the case where the approval does not require an inner receptacle in a combination packaging, the user must have provided evidence that a test for 75 kPa or 95 kPa respectively has been successfully passed.
The crucial point remains, that the packaging or the IBC must be designed in such a way that the charge does not escape under normal conditions of carriage, whereby it is clear that aspects such as vibrations, changes in temperature, changes in humidity or pressure play no role whatsoever for the issuance of the approval. In fact, for boxes made of carton exactly the opposite is prescribed: To ensure environmentally uniform test conditions, these packagings are not to be drop tested or stack tested under the real humidity conditions that are to be expected; instead these tests are to be performed under prescribed normal climatic conditions.


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5. See also (TES internal links)


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6. Weblinks (external links)


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2011-03-25
Signature TES (Start)
Technical Safety -
Dangerous Goods Containments
Databases

Database Dangerous Goods Packagings
Register of German Approvals

Dangerous Goods Database
Planning of Transport incl. Transport Documents