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Return Logistics Proposal Identifies Compliant Packaging

June 16th, 2015 by Howard Skolnik

Filed under: DOT/UN, HazMat, Skolnik Newsletter

Return Logistics, as proposed in CFR 173.157 will be defined in 171.8 as the process of moving goods from their final destination for the purpose of capturing value, recall, replacement, proper disposal or similar reason. When a manufacturer’s product normally moves through the supply chain network, it is to reach the distributor or customer. Any process or management after the sale of the product involves reverse logistics. If the product is defective, the customer would return the product. The manufacturing firm would then have to organize shipping of the defective product, testing the product, dismantling, repairing, recycling or disposing the product. The product would travel in reverse through the supply chain network in order to retain any use from the defective product. The logistics for such matters is Reverse Logistics.

For those considering the packaging options available to comply with the proposed regulation, the current proposal for selection of compliant packagings for reserve logistic movements are listed in 173.157(b) and they are:

(1) Packagings must be leak tight for liquids and gases, sift proof for solids, and be securely closed, secured against shifting, and protected against damage. Inner packagings must be secured against movement within the outer package and protected against damage under conditions normally incident to transportation. For liquids, the inner packaging must be leak proof, and the outer packaging must contain sufficient absorbent material to absorb the entire contents of the inner packaging. For solids, inner packaging must be sift proof.

(2) Each material must be packaged in the manufacturer’s original packaging if available, or a packaging of equal or greater strength and integrity.

(3) Outer packagings are not required for receptacles (e.g., cans and bottles) that are secured against shifting in cages, carts, bins, boxes or compartments. However, any compromised receptacle must be placed in an inner packaging or outer packing that will prevent spillage in transportation.

(4) The fuel tank and fuel lines of equipment powered by an internal combustion engine must have the flammable liquid fuel drained to the greatest degree possible, shut-off valves, if present, must be in the closed position, and all fuel tank caps or closures must be securely in place.

(5) Equipment powered by an internal combustion engine using flammable gas fuel, or other devices using flammable gas fuel (such as camping equipment, lighting devices, and torch kits) must have the flammable gas source disconnected and all shut-off devices in the closed position.

(6) Equipment powered by electric storage batteries must have the batteries activation switch on the equipment must be protected to prevent inadvertent activation. If the equipment is damaged to the extent that the battery or switches may not be protected, the battery should be removed and packaged separately in a manner that will protect the terminals from short circuit. Batteries should also indicate the proper orientation during transportation and storage.

(7) Aerosols must be packed to prevent inadvertent discharge of the contents from the aerosol packaging during transport. Each aerosol container must be secured with a cap to protect the valve stem.

(8) Cylinders or other pressure vessels containing a Division 2.1 or 2.2 materials such as DOT–39 cylinders and cylinders containing limited quantities of compressed gases must conform to the packaging, qualification, maintenance, and use requirements of this subchapter.

(9) Materials authorized for transport according to a special permit as defined in § 171.8 of this subchapter: (i) Each outer packaging that has not been opened and is in the original undamaged condition with the closure secure, shall be offered for transportation and transported in the original packaging as authorized by the special permit; (ii) When the inner receptacles have been removed from the outer packaging of a combination packaging and remain undamaged with closure secure they must be packed either in the original packaging authorized by the special permit if available and undamaged or packed in a suitably strong outer packaging with suitable cushioning material and securely closed. (c) Hazard communication. (1) The outer packaging, other than a cylinder shipped as a single packaging, must be marked with a common name or proper shipping name to identify the hazardous material it contains.

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