Drop testing protocol for performance standards does not specify a time at which the test is to be performed after fabrication. A recent proposal had been brought to the United Nations Committee of Experts to perform this test 24-hours after the container was prepared for testing. Determined to establish the most critical time to perform the Open Head Drop Test for a liquid, some testing was completed at the US-DOT Tobyhanna Test Laboratories. In question was whether drums dropped 24-hours after closing would fail the drop where drums closed and dropped immediately might pass. The end results showed that, in fact, the opposite condition existed and that the most difficult time to perform the drop test would be at the time of initial closure. As a result of this finding and that of other test laboratories, the 24-Hour Delay proposal was abandoned by the UN Committee of Experts.
STEEL DRUM INDUSTRY NEWS, TRENDS AND ISSUES
Archive for February, 2005
Though inconsequential to the test performance of a package, DOT markings are critical for package identification and regulation. For the most part, US packaging manufacturers are putting the required information on packaging in both durable and embossed formats, but some minor errors have surfaced. For instance, for the UN emblem, the letters “un” must appear vertically in lower case, while some are using upper case letters. If the emblem is not used, then the upper case letters positioned horizontally are required. Also, for packagings that have more than one certification, some manufacturers were noting the year of manufacture only once, when this information would have to be a part of each certified marking. CFR 178.503 specifically states the sequence for marking information. While the DOT does not consider these non-compliance issues to be a safety issue, it is best that all manufacturers and fillers verify that the markings on their packagings are compliant. Responsibility rests in the hand of the shipper.
If you are purchasing a UN certified package, it is necessary to retain Testing Certificates that are company specific, product specific and current. Outdated and incorrect document retention exposes your company to a probable violation fine from the Department Of Transportation. As stated in CFR 178.2(c); manufacturers and “each subsequent distributor” is responsible for verifying the status of the UN Certification and issuance of applicable instructions to compliance with conformance. This also includes Closure Instructions. Therefore, if one is re-selling a package that is given an invalid UN mark without a current Closure Instruction, the re-seller is also liable for violation fines. The best way to protect all purchases from this type of exposure is to require current UN certificates with each purchase, verify the information upon receipt and maintain a log of expiration dates of all products bought and sold.