Ken Hardman, quality/health & safety manager for Van Leer (UK)and active participant within the Association of Drum Manufacturers (ADM) for over 23 years, comments on the current state of industry regulations for testing kegs, pails and steel drums and presents the potential problems this poses for manufacturers and customers alike
"Over recent years, much has been said and documented on current UN legislation for testing of steel packaging and the effect it has throughout Europe. The concern from manufacturers such as Van Leer is that UN certification does not mean standardisation in quality of testing - a fact we can not assume is recognised by the customer.
In the UK, testing of steel packaging is extremely diligent. PIRA and the Department of Transport stipulate that UK test houses must be UKAS accredited to ISO Guide 25, and are re-evaluated annually. Every change to a keg, pail or steel drum is tested and 'information drops' are also performed to assess the weakest point of the product. This is not a procedure detailed by the UN, therefore, some other European countries do not operate it as diligently.
Inevitably, a major factor facing the manufacturing industry is cost. For example, in the manufacture of kegs for liquids, in order to meet stringent performance tests, the lid should contain substantial material, and must have a secure fit to the drum body.
Product performance is geared to material thickness - the thinner the material, the lower the performance. Something with less material is more cost-effective for the manufacturer, but could ultimately be more costly for the customer.
Currently, manufacturers of steel drums, kegs and pails throughout Europe refer to the UN document, Transport of Dangerous Goods - Model Regulations for packaging specifications and requirements for testing. However, the requirements set out within the Drop Testing section, can give rise to different interpretations. The effect in the market is that products are being tested to varying quality levels depending on the interpretation of the individual country, and individual test house. Van Leer is asking for a 'level playing field' to ensure quality. So, how can quality of performance be guaranteed?
Van Leer, the Association of Drum Manufacturers (ADM), and many other industry bodies believe a universal standard for performance testing via a European Committee for Standardisation (CEN) standard, would ensure that all containers for UN certification were tested to the same specification, and therefore, the same quality. However, even with strong industry pressure, we are still some way off before this is established.
In the early 1990s a submission was made to the CEN to raise the problem of variations in testing. A draft testing standard has been drawn up subsequently by CENTC261/SCI/WG6 and was submitted to the CEN in April 1998. Although CEN administration have delayed the draft standard, it is due to be published for public comment over the coming months. It will then pass through the CEN cycle of review, voting and finalisation - a slow process. The finalised standard is unlikely to be published until late 2000.
What can be done in the meantime?
At present, testing in individual countries is the responsibility of the Competent Authorities. In general, Competent Authorities are the Department of Transport of that country as they deal with the transportation of dangerous goods.
The forms the basis of a major hurdle. Steel packaging contains and transports a wide variety of products including non-hazardous and hazardous substances. Statistically, the number of accidents as a result of failed packaging is minimal, therefore Competent Authorities are reluctant to 'rock the boat'.
The UK procedure is that the offending substandard packaging has to be tested by the UK interested party, for example, the ADM and a UKAS test report s submitted via PIRA to the DETR. The DETR then request the relevant foreign Competent Authority who have approved the design type to carry out an investigation. This is a tedious process and during this period, there is reluctance by the DETR to request that the offending package is publicly recalled from the market place by the importer or manufacturer.
Another consideration is cost to the end customer. Packers/Fillers are under constant pressure to cut costs, and some are purchasing cheaper imported containers. What they do not consider is that they could be using a cheaper quality product that has not tested as stringently as others that are available.
Ultimately, in terms of transportation, it is the shipper's responsibility. If they see that products are filled satisfactorily in permitted UN marked packaging, then they have fulfilled their responsibility. Therefore it is back to the Packer/Fillers to make sure that the drum is totally suitable for its purpose.
Until the CEN standard is approved, Van Leer believe it is the responsibility of the manufacturers to produce safe, quality products, tested to the highest levels. With the different interpretation of UN testing procedures, some manufacturers are gaining competitive advantage by legitimately manufacturing cheaper products. Purchasers and shippers could be falsely led into believing that all drums bearing the same UN marking have been tested to the same performance standard.
Although manufacturers have a responsibility to produce quality products, users also have a responsibility to play. In order to be totally satisfied that the product is fit for its purpose, they should look beyond the UN Mark and take into consideration important physical attributes of the packaging. Just because a product bears a UN mark does not guarantee quality of performance - ignorance is no defence."
More on This Topic:
Accidents Waiting to Happen by Ken Hardman - July 1999
Thin Skinned by Peter
Mackay (in response to Ken Hardman) - September 1999
Letter to the Editor
from Howard Skolnik (in response to Peter Mackay) - September 1999
Letter to the Editor
from Martin Castle (in response to Peter Mackay) - October 1999