An insightful examination of the tangled
relationship between dangerous goods
regulations and compliant packaging.
Industrial Packaging for
Hazardous materials packagings have
been regulated in the U.S. by both
governmental and private organizations
since the early 1900s.
First by the Bureau of Explosives (BOE);
later by the Interstate Commerce
Commission; then DOT (1967)
In 1974, the Hazardous Materials
Transportation Act consolidated all DOT
regulatory authority in the Materials
In 1977 RSPA was formed.
Today, hazmat regulations are controlled
by PHMSAs Office of HazMat Safety
BOE and ICC loosely regulated hazmat
packaging (avoid leakage).
By 1967, regulatory controls over
packaging expanded and
“specification” packaging was created.
Specification packaging was rigid and,
at times, almost funny.
DOT 15 box (group 2 hazmats)only made
› Southern yellow pine
› NC pine
› Douglas Fir
Spec packaging testing rules were rather
› Tests 3 times per year
› Test samples retained (one year)
› Drop (4 ft.)
› Hydro (20 p.s.i. for 5 minutes)
› Leakproofness (15 p.s.i. water or soap over
Closure requirements existed, but only for
Sample closure requirement (1985)
(a) Adequate to prevent leakage;
(b) Closing part (plug, cap, plate, etc.,)
must be made of metal as thick as
prescribed for head of container….
Federal hazardous materials
transportation law directs the Secretary
of Transportation to establish regulations
for the safe and secure transportation of
hazardous materials in commerce…
…and to persons who manufacture or
maintain packaging of a component of
packaging that is represented, marked,
certified or sold as qualified for use in
transportation of hazardous material in
HM Packaging Manufacturers
Anyone who may participate in other
related transport over public right-of-
All packagings designed to transport HM
National Governments (e.g. DOT; TDG)
United Nations (Global
IATA and ICAO (air)
ADR ( Road)
Skolnik manufactures about 150 different
packagings that are UN certified.
DOT requires packaging designs to be
recertified every 12 months.
Skolnik is a self certifier and does its own
Taking you into our Test Lab and focusing
on set up and performance of an
individual UN Design Type Test.
› Huge percentage of failures for all
packaging design types
› No failure analysis
› No subsequent action (except a few fines)
› Publish results on web; no explanation
› Alternative Design Validation Testing – not
› Does not reflect field performance
Tobyhanna moved from policing to
Tobyhanna test results available on line
What to do when the DOT calls!
1. Always anticipate an inspection
2. Run a self audit once per quarter
3. Keep copies of all necessary DOT
records (e.g. employee training) in one
location. Be sure another person knows
where the records are kept.
4. Be sure employees can answer basic
questions DOT might ask (e.g. have
you been trained in this job function).
5. Accompany the DOT inspector as he
conducts the inspection. Record key
actions on paper.
6. Get the inspectors name.
7. Keep exit briefing form(s).
8. Fix all noted problems.
9. Call your lawyer.
Thank you! Did you learn something new?
Stories to share?