Letter to the Editor

From the Hazardous Cargo Bulletin, September 1999

TO: Mr. Peter Mackay, Editor
Hazardous Cargo Bulletin

FROM: Howard Z. Skolnik, President
Andrew M. Castle, Testing and Regulatory Coordinator
Skolnik Industries, Inc.

DATE: 05 August 1999

SUBJECT: "Accidents Waiting To Happen" (July 1999)

Dear Mr. Mackay:

From about 1908 to 1991, Specification Packaging was the global standard applied to the construction and testing of dangerous goods packaging. During the 1970's, there was a major thrust to replace specification packaging with a system that would allow for innovation in design and material content, with test criteria being the ultimate qualification. As one of the more forceful proponents of the Performance Oriented Packaging (POP) system, we are delighted to see that Mr. Hardman and Van Leer suggest that some standardization and minimums are needed in order to equalize the integrity of dangerous goods packaging worldwide. Therefore, we would like to comment on and reinforce several of the statements made by Mr. Hardman on behalf of Van Leer:

We completely agree with Van leer and share their concern that a UN marked package is not a guarantee that a package has been manufactured correctly. Though overseen by competent authorities worldwide, testing protocol does differ between manufacturers. Like Van Leer, Skolnik tests throughout the year performing certification tests and a stream of customer specific tests. This overtesting insures that the quality of our products is not only of high integrity, but helps us to refine our products so that risk in the field is reduced.

As a new container manufacturer whose packages are used for the shipment of extremely hazardous materials, Skolnik is relieved that a global industry leader such as Van Leer, recognizes that package performance depends entirely on the material thickness and that thinner material results in poorer performance. We agree with Van Leer that material thickness is by far, the largest contributing factor to the ability of a package to perform to the desired level, and function safely in the field. Therefore, it would be wise to standardize the minimum thickness of new containers. Van Leer states that the use of thinner gauge material might reduce costs in the short term to both the manufacturer and the end user but the danger and liability that results through the use of these packages in the field, outweighs the reduced cost, short term solution.

Skolnik is also happy that Van Leer recognizes that those manufacturers who produce "lighter gauge containers" are damaging the reputation of the producers of more substantial containers. It has been our experience that when a purchasing agent moves to lighter containers and they fail in the field, the buyers do not return to the original heavier gauge package. Instead, they seek an alternative type of packaging. This pattern has done irreparable damage to the reputation of the steel drum and, as a result, diminishes future business opportunities for the industry.

We agree that the manner of testing is critical in determining the quality of the product. As a result it is not a matter of who performs the testing but the manner in which the tests are performed. It is the responsibility of the container manufacturer to ensure that all of the containers that they produce are capable of passing the prescribed tests in accordance with the prevailing competent authorities regulations.

It is not only the manufacturer's responsibility to ensure that their containers are qualified products, it is also the responsibility of the Competent Authorities to give the assistance necessary to ensure compliance. In addition to providing assistance, the Competent Authority is responsible for enforcing and monitoring the manufacture and transport of dangerous goods so that customers, end-users and the general public can have confidence that the package they are using is sufficient for the task, and that the system in place is capable of allowing the safe transport of dangerous goods.

Experience has shown that third party testing does not necessarily result in a quality product. If, as Ken Hardman states, packages that originate from certain European countries perform less well than those manufactured in other countries. The problem is not that some countries have third party testing and others don't, the problem is that some countries enforce it and others do not.

Finally, we believe that the methodology of testing is important and that standardization of testing is critical. We agree with Van Leer that the current trend towards using lighter gauge materials does contribute more significantly to package failure. A well manufactured, light gauge container will generally be out-performed by a less well made heavier gauge container. For a short period of time drums manufactured for hazardous materials in South Africa and Brazil had been as light as 0.6mm (24 gauge) and based on Van Leers statements on this issue, we concur with them not to support these practices. We believe that it is critical that the issue of material thickness be standardized with minimum requirements, and agree with Van Leer that manufacturing packages with heavier gauge material should become a global standard. The test guidelines that are described in the Orange Book are sufficient for the time being. These could be revised and improved upon in the future as more information on the performance of containers comes to light. We agree with Van Leer that it is material thickness that plays the most important role in the performance of a package.

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

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