UN packagings are fabricated and tested to specific levels of performance. These tests allow a manufacturer to mark the packaging with the appropriate testing criteria (ie: packing group, maximum gross weight, contents). Often, users innocently alter the integrity of the package by adding accessories (ie: a plastic liner) or by replacing accessories with different components (ie: closure ring, gasket) in which case, the certification of the package can be voided if not re-tested for qualification. “A different packaging” is defined in CFR49 178.601(c)(4) as a packaging that differs from a previously produced packaging in structural design, size, material of construction, wall thickness or manner of construction. Further design qualification testing is not required if the alterations to the packaging do not constitute “a different packaging.” Also, Closure Instructions are packaging specific and must be used only for the packagings as designated.

View our Closure Instruction videos at:

Bolt Ring — https://www.skolnik.com/bolt-ring-closure-instruction-video

Level Lock — https://www.skolnik.com/leverlock-open-head-closure-instruction-video

Fittings — www.skolnik.com/closed-head-closure-instruction-video

PHMSA plays a leading role in ensuring the safe transportation of hazardous materials in commerce throughout the United States. As a result of the ongoing Coronavirus Disease 2019 (COVID-19) public health emergency, certain shipments of COVID-19 diagnostic samples (e.g., nasal swabs, vials of sputum, and other related items) are classified as a Category B infectious substance (Division 6.2) hazardous material under the Hazardous Materials Regulations (HMR).

Recent compliance inspections and found several instances of improperly marked or packaged diagnostic samples that were offered for transportation. In response, PHMSA is issuing this Safety Advisory Notice to provide information on the HMR related to offering and transporting these materials.

While steel drums may look alike, once they are United Nations certified for hazardous materials, they are as unique as the manufacturer. The entire design of a UN drum, and all its components (metal thickness of the body and heads, ring type, gasket, bolt, nut, plugs), is set and defined when being subjected to the Performance Oriented Packaging Standards per CFR 178.600, the US Code of Federal Regulations. The specific components used to perform the test comprise a drum type, or certification, that must meet a designated test standard for classified HazMat products. Once in the field, shippers cannot alter or interchange any of these components, even though they may appear similar, changing these features will impact the ability of the drum to perform as certified. This also applies to the required Closure Instructions per CFR 178.2(c), which are required to be given to the shipper by the specific packaging manufacturer. If replacement parts are needed, fillers must make sure that they get the originally tested components from the manufacturer. Once a drum enters transportation, compliance with the UN Certification is the responsibility of the shipper. Failure to comply with the UN certification may result in a fine from the DOT.