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DOT, Really???

June 20th, 2013 by Howard Skolnik

Filed under: Associations, DOT/UN, HazMat, Industry News

At a Packaging Roundtable meeting at the recent annual Council on the Safe Transport of Hazardous Articles (COSTHA) conference in San Diego, members were discussing issues relative to the DOT’s Test Validation Program, aka Tobyhanna. The DOT submits packagings that they purchase in the public domain and validate, or retest, the packagings performance to the UN markings on the specific package. Over the years, there have been countless comments regarding inconsistent testing procedures and excessive testing demands — sometimes beyond the requirements of the Code of Federal Regulations, but a story that I heard at the Packaging Roundtable takes 1st place among the Closure Instruction requirements that, in my opinion, are meaningless to the packaging’s performance and the safe transport of dangerous goods.

A UN certified cardboard box was purchased and sent for testing at Tobyhanna. As a part of the pretest qualification, the weight of the box was checked against the weight of the Performance Test documentation and a discrepancy of a few grams was found. What is curious about this is that the CFR calls out that the metric weight of the box, in kilograms, would have to be identified, however, in this case, they were looking for grams of difference. After reviewing the construction of the box, the test lab determined that the Closure Instructions did not specify the amount and dimensions of tape used for compliant closure and that if they specified the length and width of the tape used to close the box, this piece of tape would make up for the missing grams. To measure the weight, they took a piece of the specified tape, crumpled it into a ball, and weighed it. The final determination was that the Closure Instructions for the box had to be modified to specify the tape requirement for compliant closure. I am not aware if the box manufacturer was dealt a fine for the violation.

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