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DOT Inspectors Target Records Retention

November 12th, 2008 by Matthew Dick

Filed under: DOT/UN

As DOT inspectors continue to visit hazardous material container manufacturers and shippers, part of their inspection often includes a review of the documents on file. Documents pertaining to the UN test certification must be retained. Whether manufacturing a new or reconditioned container, or filling and shipping, the test log and report for each specific design type of container must be retained. In addition, all current reports must be held for at least two years after the end of the final production run of that design type. The test report must contain (at a minimum) the following information: 1) Name and address of the test facility; 2) Name and address of the applicant; 3) A unique test report identification; 4) Date of the test report; 5) Manufacturer of the packaging; 6) Description of the packaging design type (eg: dimensions, construction materials, closures, wall thicknesses, etc.) including methods of manufacture (eg: lap or butt welding, blow molding, etc.) and which may include photographs, drawings or videos; 7) Maximum capacity; 8) Characteristics of the test contents (eg: viscosity and relative density for liquids and particle size for solids; 9) Test descriptions and results; and 10) A signed report with the name and title of signatory. A test certification that does not include, at least, all of this information can be determined to be incomplete and non-compliant. Prevent a possible fine from DOT and verify that; 1) you have these documents on hand; 2) that they are current; and 3) that they are complete.

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