Oops! Can You Pass the Nonbulk Hazmat Drop Test?

You’re preparing to transport some nonbulk hazardous material in a combination packaging that consists of a solid plastic container with an inner 3-millimeter (mil) polyethylene bag. Is it OK if the inner packaging develops punctures and ¼ -inch to ½ -inch (in.) holes upon impact if there is no leakage of the filling substance?

Well, no!

The Pipeline and Hazardous Materials Safety Administration (PHMSA) has testing requirements for various packaging scenarios. One of these tests is the drop test, i.e., would the package and materials inside maintain their integrity if dropped from certain heights. Today we will discuss the general drop test requirements for nonbulk packagings/packages.

Who—Me?

While as a hazardous materials shipper you may think that you are not responsible for making sure a package passes the drop test, but think again. Although it is the responsibility of the packaging manufacturer to assure that each package can pass the required tests, including the drop test, since a package assembly function, including final closure, is performed by the person who offers a hazardous material for transportation (the shipper or offeror). The offeror must determine that the packaging or container is an authorized packaging, and that it has been manufactured, assembled, and marked in accordance with, in part, all the testing requirements.

When You Drop Nonbulk Packages

Nonbulk packages for the purposes of transporting hazardous materials are those that contain:

• 119 gallons or less of a liquid;
• 882 pounds (lb) or less of a solid; or
• 1,000 lb or less of a gas

The drop test discussed here is for nonbulk packages containing most hazardous materials. Note: There are additional drop test requirements specific to nonbulk packages containing infectious substances.

For packages containing nonbulk hazardous materials other than infectious substances, there are specific drop test requirements, found at 49 CFR 178.603, for:

• Drums and barrels of all types (e.g., metal, wood, fiber, plastic, composite)
• Boxes of all types (same examples)
• Bags, both single- and multi-ply

How to Prepare for the Drop

Except for inner packagings, plastic bags that are intended to hold solids or articles, drop testing of plastic drums, plastic jerricans, plastic boxes other than expanded polystyrene boxes, composite packagings (plastic material), and combination packagings with plastic inner packagings must be carried out when the temperature of the test sample and its contents has been reduced to −18°C (0°F) or lower. Test liquids must be kept in the liquid state. If need be, you can add antifreeze.

The target that a package is dropped to must be hard and flat. The drop height depends on the packing group of the material and whether, if a liquid, the test is performed with water. In every case, the height is highest (up to 5.9 feet) for materials in Packing Group 1, which is the packing group for the most hazardous materials.

Did You Pass the Drop Test?

To pass the drop test:

• Packagings containing liquids must not leak when equilibrium has been reached between the internal and external pressures. However, it is not necessary that the pressures be equalized for inner packagings of combination packagings.
• For packagings with removable head drums for solids, even if the head of the drum is no longer sift-proof, the entire contents must be retained by an inner package (e.g., a plastic bag).
• The outermost ply and the outer packaging of a bag must not show any damage that would adversely affect safety during transport.
• For a composite or combination packaging, the packaging or outer packaging do not show any damage that would adversely affect safety during transport. Anything inside must remain completely within the outer packaging, and there must be no leaks from the inner receptacles or packagings.
• Any discharge from a closure must be slight and stop immediately after impact.
• For Class 1 materials (i.e., explosives), there must be no ruptures that would permit spillage of loose explosives from the outer packaging.

Scenario

In the scenario concerning transporting a nonbulk hazardous material in a combination packaging that consists of a solid plastic container with an inner 3-mil polyethylene bag, a company asked PHMSA if it is acceptable if the inner packaging develops punctures and ¼ in. to ½ in. holes upon impact if there is no leakage of the filling substance.

According to PHMSA officials, it is not acceptable.  An inner packaging of a combination packaging that develops punctures and ¼ in. to ½ in. holes after the drop test has failed the drop test. PHMSA’s reasoning is that the inner packaging’s inability to resist punctures and holes during testing can be indicative of its integrity under transportation conditions.

Tune into tomorrow’s Advisor for some tips for drop testing intermediate bulk containers (IBCs).