With the introduction of Performance Oriented Packaging in the 1990’s, UN certification of packagings in the US were either performed by a self-certifying manufacturer (CFR 178.503(a)(8), (f)(6)) or by sending packagings to a third-party test lab. Whether self-certified or lab tested, the protocol for performing the non-bulk UN tests is spelled out in CFR 178.600, but, with the DOT’s Tobyhanna Test Lab claiming that packaging’s are failing their validity testing, many of the third-party test labs came together to examine the differences between their test procedures.
The labs established 6 test subject groups in order to examine the following: report requirements, conditioning, filling substances, pressure testing, drop testing, and stack testing.
Examples of the protocol concerns include issues such as: identification of key information required for a completed certification report, whether a fill substance is affected by the testing environment temperature, clarification of the compression or freestanding weight systems used to demonstrate stack height, and the correct equipment and methodology necessary to properly perform a hydrostatic test. This meeting indicated that there are many questions that need to be answered in order for test labs to perform their tests consistently. It looks like a long road ahead, but one that will greatly benefit all HazMat shippers that suffer non-compliance actions due to improper testing.