TES Technical Safety - Dangerous Goods Containments
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Questions and Answers

1. Search and Find

Finding authorized packagings

Database Dangerous Goods Packagings
Register of German Approvals


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How do I find the correct approved packaging

Look under Usage


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Finding manufacturers of certain packagings, e.g. 6HA1, 6HG2 …

Database Dangerous Goods Packagings
Register of German Approvals


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Finding all approvals of a certain manufacturer

Database Dangerous Goods Packagings
Register of German Approvals


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Test offices - what test offices are there other than the BAM?

In Germany, the Federal Institute for Material Research and Testing is the authority responsible for testing packagings, intermediate bulk containers (IBC) and large packagings (LP).

However, the BAM has additionally named a number of recognised test houses that may also perform these tests, and which you may also approach. The list of BAM-recognised test houses shows the following remark: "recognised for". This is followed by a list of the type codes for which this particular test office has been recognised.

We also have a list of the test houses that are available worldwide (as far as these may be known to us). The list can be found under Abroad


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3. Packaging Regulations

Is there a packaging regulation that specifies how and with what the dangerous goods packagings must be sealed?

The Issue:

Is there a packaging regulation for dangerous goods boxes (4G) that provides information about with what and how dangerous goods boxes can be closed? Alternatively, the issue concerns a regulation concerning how a customer closes a box using a filament adhesive tape. (Question forwarded by an intermediary trader)

Antwort:

There is no gerneral regulation governing the closure of dangerous goods packagings, and thus also no specific regulation for boxes made of cardboard. The following general principle applies: packagings must be closed in the same way that they were closed when they passed the prototype test. Thus the information concerning the type of closure and, for example, the tear resistance of the adhesive tape to be used, can be found in the test report for the approved type. Where appropriate, there may also be additional information in the approval certificate of the approved closure means.

The following new regulation has been added to the valid dangerous goods regulations to implement this principle (see 6.1.1.5 of ADR):

Manufacturers and subsequent distributors of packagings shall provide information regarding procedures to be followed and a description of the types and dimensions of closures (including required gaskets) and any other components needed to ensure that packages as presented for carriage are capable of passing the applicable performance tests of this Chapter.

From this follows, that the intermediary trader must obtain this information. The manufacturer is obliged to do so. On the other hand, you as a "distributor" are obliged to pass the information on to the customer.

Otherwise this principle applies also for the approved inner packagings: The box must be filled only with the tested inner packagings. Other inner packagings may be used without further testing only if the conditions specified in ADR 6.1.5.1.6 are upheld. These regulations can be upheld only when you and your customer know what inner packagings and what content (liquid and/or solid) were used when the type test was passed. You are thus required to obtain this information and pass it on accordingly. Inner packagings other than those of the family specified in 6.1.5.1.6 may only be used when you have ensured that the packaging is equivalent to the tested prototype. Proof of such equivalence can generally be obtained by means of an edge drop test performed on the packaging using the "new" inner packagings.


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4. Marking

Dual allocation of a manufacturer marking

The Issue:

A company has purchased a plasticjerrican wholesale from a competitor who uses the same manufacturer identification. However, a further mark on the jerrican shows that the item involved is a jerrican that has been approved in Hungary. The manufacturer identification used is not a registered trade mark. Is it possible to prevent such a dual allocation of a manufacturer identification?

Answer:

ADR 6.1.3.1
The marking consists of various elements including
(...)
g) the name of the manufacturer or other identification of the packaging specified by the competent authority.

Since there is no Europe-wide and definitely no world-wide agreement between the competent authorities concerning the coordinated allocation of manufacturer identifications, such dual allocation of marks cannot be prevented.


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What is the difference between the UN marking and an UN number?

1. UN Marking

UN markings are applied to the packagings.

The marking indicates, that the packaging which bears it corresponds to a successfully tested design type, and that it complies with the regulations of (...) related to the manufacture, but not to the use of the packaging. Consequently, the marking does not necessarily state that the packaging may be used for any substance (...).

The purpose of the marking is to simplify the work of packaging manufacturers, reconditioners, packaging users, shippers and regulatory authorities.

For regulations and examples on marking, please consult the following Legal Bases chapters:

Shipment by land: ADR /RID Chapter 6.1.3
Shipment by sea: IMDG-Code Chapter 6.1.3
Shipment by air: IATA: Part 6, Chapter 2 Marking of Packagings other than inner packagings

The marking on a drum with liquid content would, for example, appear as follows: Picture of UN Marking. 
					The explanation can be found in the table

The meanings of the individual components of the UN marking are as follows:

UN Symbol of the United Nations (UN in a circle)
1A1 Code indicating the name of the type of packaging
Y Y = Packaging Group II;
(Note: Dangerous goods of Packaging Group III may also be transported in a packaging of Packaging Group II, provided that this packaging is admissible for these particular dangerous goods.
1.4 Relative density, for which the prototype was tested
150 Test pressure in kPa (Kilopascal) of the hydraulic internal pressure test
02 Year of manufacture
D/ Symbol of the country that issued the approval
BAM Approving authority/institution
4711 Test certificate number
XY Manufacturer identification specified by the responsible (approving) authority
2. UN Numbers

UN numbers are assigned to dangerous substances and dangerous goods. This list can, for example, be found in Table A, Chapter 3.2 of the ADR.

There is a UN number assigned to each entry in the various classes. The following types of entries are used:

  • Individual entries
    for precisely defined substances or objects, including entries for substances that cover various isomers, e.g.: UN 1090 ACETONE
  • Generic entries
    for precisely defined groups of substances or objects that do not come under n.o.s. (not otherwise specified), e.g.: UN 1133 ADHESIVES
  • Specific n.o.s. entries,
    that encompass groups of not otherwise specified substances or objects of a certain chemical or technical constitution, e.g.: UN 1477 NITRATES, INORGANIC, N.O.S.
  • General N.O.S. entries,
    that encompass groups of not otherwise specified substances or objects with one or more dangerous properties, e.g.: UN 1325 FLAMMABLE SOLID, ORGANIC, N.O.S.

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Legibility/visibility of the UN marking

The Issue:

Certain drums were manufactured abroad in compliance with a foreign approval and then delivered to the user in Germany. The drums are painted black, the UN marking was embossed, but it does not stand out from the background in a different colour.

Answer:

ADR 6.1.3.1
Each packaging intended for use according to the ADR shall bear markings which are durable, legible and placed in a location and of such a size relative to the packaging as to be readily visible. For packages with a gross mass of more than 30 kg, the markings or a duplicate thereof shall appear on the top or on a side of the packaging. Letters, numerals and symbols shall be at least 12 mm high, except for packagings of 30 litres or 30 kg capacity or less, when they shall be at least 6 mm in height and for packagings of 5 litres or 5 kg or less when they shall be of an appropriate size.

Since the packaging here was manufactured in compliance with a foreign approval, the user is required to contact the respective foreign approval office to determine whether he may use this packaging or not.

If the packaging had been manufactured in compliance with a German approval, the user could (after consulting with BAM) apply a method to colour the UN marking so that it stands out against the background and is thus legible and easy to see.


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Should the label be applied before filling?

The Issue:

Must a type-approved waste disposal container (1H2; UN 3291) always be disposed of as special waste as soon as it labelled with the danger class 6.2 "Infectious substances" marking, independent of the actual risk class of the substance that it is filled with? The background to this question is, whether it is sensible to label these containers with the danger class 6.2 marking right at the factory, or whether it would be more appropriate for the user to apply the labelling.

Answer:

According to the Dangerous Goods Regulations, it is always more appropriate to apply the label when the substances with the corresponding danger have already been placed in the packaging.

Also, the label should be left on the packaging if the packaging has been emptied of the dangerous substance but has not as yet been cleaned ("uncleaned empty packaging").

In the reverse argument, the applied danger class 6.2 marking could lead to the conclusion that the packaging once contained a dangerous substance with this danger characteristic, so that the packaging should be sterilized - i.e. cleaned - or that it should be disposed of as special waste.

Otherwise, strictly speaking, a label that is not relevant to the situation would have to be removed. That would be the case if the packaging is either brand new or it has been cleaned.

However it is common practice that, for example with bags or boxes made of paper / fibre board, such brand new packagings are delivered to the customer factory fitted with the label for the respective dangerous substance that they are to carry. When we encounter a truck loaded with such packagings, then where bags and folded fibreboard boxes are concerned, it is generally clear that these do not and did not contain dangerous substance. However this practice is not accounted for in the Dangerous Goods Regulations, so that, particularly where other packaging types are concerned, the question arises for supervisory bodies and inspection authorities, whether the dangerous substance is or was in the packaging.


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5. Certain Types of Dangerous Goods Packagings

What types of dangerous goods packagings are there?

1. "Classic" packagings

Capacity < 450 liters or net weight < 400 Kg

These include "combination packagings" and the design series of boxes made with fibreboard as well as the packagings under (4)

2. Intermediate bulk containers (IBC)

Capacity max. 3.0 m³

3.Large packagings (LP)

Outer packagings that may contain objects themselves or inner packagings

Net weight ≥ 400 kg at the design type test or capacity of more than 450 liters, but max. volume 3.0 m³

4. Packagings for Class 6.2 dangerous substances (infectious substances)

These also include "classic" packagings

5. Packagings for Class 7 dangerous substances (radioactive substances)
6. Pressure receptacles (pressure cylinders, large pressure cylinders, pressure drums and cylinder bundels)
7. Closed cyrogen containers

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Combination packagings

Combination Packagings - A Special Case

We frequently meet the view that, when shipping dangerous goods in combination packagings, it is only necessary to ensure that the gross weight specified in the UN coding is not exceeded; but other than this, it would be permitted to simply pack the inner packaging into the approved outer packaging, e.g. a box made of corrugated cardboard. However, as already indicated above, things are by far not as simple as this. Every policeman will admit that, under normal conditions he would not open such boxes to verify that the corresponding regulations are being adhered to. However, if dangerous substances are released during carriage, or perhaps even persons are injured, there is always the question of who is "guilty", and this will apply here just as much as elsewhere.

From the basic principle it is completely clear that only those inner packagings including content, with which the type test was performed, are also approved for usage. This can, for example, be derived from the sentence in 6.1.5.2.1, where it states that "For combination packagings where the inner packaging is designed to carry liquids and solids, separate testing is required for both liquid and solid contents." Furthermore, a pass criterion in the drop test is that no filling material is permitted to emerge from any of the inner packagings!

Strictly applied, this principle would lead to very impracticable consequences. For this reason, the regulations have been supplemented by a passage that permits the use of other inner packagings under certain conditions, even without an additional test.

4.1.1.5.1 Where an outer packaging of a combination packaging has been successfully tested with different types of inner packagings, a variety of such different inner packagings may also be assembled in this outer packaging. In addition, provided an equivalent level of performance is maintained, the following variations in inner packagings are allowed without further testing of the package:

  • a) Inner packagings of equivalent or smaller size may be used provided:
    • the inner packagings are of similar design to the tested inner packagings (e.g. shape - round, rectangular, etc.);
    • (ii) the material of construction of the inner packagings (glass, plastics, metal, etc.) offers resistance to impact and stacking forces equal to or greater than that of the originally tested inner packaging;
    • (iii) the inner packagings have the same or smaller openings and the closure is of similar design (e.g. screw cap, friction lid, etc.);
    • (iv) sufficient additional cushioning material is used to take up void spaces and to prevent significant movement of the inner packagings; and
    • (v) inner packagings are oriented within the outer packaging in the same manner as in the tested package.
  • b) A lesser number of the tested inner packagings, or of the alternative types of inner packagings identified in (a) above, may be used provided sufficient cushioning is added to fill the void space(s) and to prevent significant movement of the inner packagings.

One thing certainly becomes clear from the above. A packager or shipper can only really meet up to his responsibilities under this regulation if he knows precisely with what inner packagings and with what inner facilities the type test was performed. Otherwise he would be in no position to make the comparison required in the regulations.

German users of approved packagings have two further ways for providing the proof required. In BAM approvals for combination packagings there is frequently the following condition: "Packagings with other inner packagings may also be covered by the approved design type, if it is proven and documented by corresponding tests that the combination packaging with these particular inner packagings meets the test requirements of the legal provisions according to Numeral 1".

A user can meet these requirements, for example by subjecting test specimens of his inner packagings to the drop test and successfully passing this test. In such a case it would be appropriate to use the services of a BAM-recognised testhouse, which has sufficient specialist knowledge to perform such tests. A larger number of manufacturers of approved boxes made of cardboard or wood are also BAM-recognised testhouse, who, after completing a corresponding test, can issue to users concise test reports concerning the successful completion of such tests.

Another way to go about this is via the Design Series (see there).


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Design type series - One approval for many packagings

Design Series for Boxes made of fibreboard

If the inner receptacles do not fit into the existing approved outer packaging, there is yet another way to obtain a solution without requiring the efforts of BAM, e.g. if the box is part of a design type series: Based on the regulations of RID/ADR subsection 6.1.5.1.2, the BAM in collaboration with the manufacturers of boxes made of fibreboard and wood has developed a design type series for boxes that meets both the interests of box manufacturers as well as the safety needs of the Dangerous Goods Regulations.

Provided that a corresponding approval certificate exists, this means that users can customize boxes for their particular requirements, as long as they remain within the smallest and the largest design type size with respect to gross weight and volume.

Example representation of a mass-volume diagram

Since generally the gross masses of the test specimens are not identical, and it is also not possible to refer to a fictitious (calculatory) density, that is constant, the mass-volume diagram is used as a basis for defining the design type series.

The mass-volume diagram is used to map out the volume and gross mass of each individual tested packaging (at least two), and these points are then joined in the diagram. All boxes that can be mapped out either below or above the line shown (point 1) in this drawing, can generally be assigned to the gross masses of the design-type series test-specimens (largest and smallest packaging), provided they pass a shortened type test.

This shortened type test consists of a single drop test. The drop test is to be performed in such a way that the largest possible damage can be expected. If this position cannot be clearly determined, several drop tests are required. The test must be documented and the test report must be submitted to BAM.

The approvals granted for such "design type series" form the basis for an unbureaucratic proof of usability in this complex field, when the user, the manufacturer of the packaging and the test office follow up on their respective responsibilities.

For further details, please see BAM-GGR 006 (BAM-Dangerous Goods Procedural Rule 006).


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5. Dangerous Substances / Dangerous Goods

What is the difference between dangerous substances and dangerous goods?

Dangerous Substances

are substances or objects that may release dangerous substances while they are being used.

When classifying dangerous substances, basically the effect of continuous occupational contact with persons, and thus also the chronic effect of the substance, is considered.

Dangerous substances tend to have lower limit values in their classification than the corresponding dangerous goods.

Dangerous Goods

are principally the above named dangerous substances and objects, which, because of their nature, their properties or their condition, in combination with the fact that they are being transported, present dangers to public saftety and order, in particular to the general public, to important common property, to the life and health of humans as well as to animals and things.

When classifying dangerous goods, basically the effect of a single contact with persons in an accident (acute effect of a substance or an object) is considered.


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Notes on classification

Manual of Tests and Criteria (Performing the classification yourself)

UN publication " Recommendations on the Transport of Dangerous Goods"
Manual of Test and Criteria. 5th revised edition.

Finding Authorized Packaging (Classifying dangerous goods/substances for certain packagings)

The packaging that is approved for usage in a particular case depends on the type of charge that is to be carried with it. You will find instructions on how to select the correct packaging under the menu "Usage".

Seaching for Dangerous Goods/Substances

The quick-info service in the Dangerous Goods Database (free of charge) can be used to enter the name of the substance or its UN number. If the user finds the required information via the substance name, he can then proceed according to the instructions provided under ("Finding Authorized Packaging").


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6. See also (TES internal links)


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7. Weblinks (external links)


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2011-01-18
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