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Module 7: Packaging

Package Selection General Packaging Requirements Using Ice Chests for Sample Shipments. Module 7: Packaging. VS.

kelsey-scott
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Module 7: Packaging

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  1. Package Selection General Packaging Requirements Using Ice Chests for Sample Shipments Module 7: Packaging VS.

  2. Comprehensive revisions to the hazardous materials shipping regulations take affect on January 1, 2011. As a result of these changes, this entire training program will be replaced on January 1, 2011. YOU MUST COMPLETE THIS TRAINING BY MIDNIGHT DECEMBER 31, 2010 OR YOU WILL BE REQUIRED TO RE-ENROLL IN THIS TRAINING AND START OVER! If you complete this training this year, you will have completed your training obligation and you will not be required to repeat this training until your training is up for renewal 2 years from the date of completion. If you believe you cannot complete this training by the end of 2010, please contact the ARCADIS Training Center to cancel your enrollment. IMPORTANT – READ

  3. Introduction Classification • Now that you have reviewed packaging terms and types of packagings, in this module you will learn about package selection, using Packing Instructions and general packaging requirements. • You will also learn about when it is appropriate to ship hazardous materials in a standard ice chest. • Finally, you are going to learn how to sift proof a dump truck. Big fun awaits you in this module! Identification Packaging Marking, Labeling and Placarding Documentation Exceptions and Limitations Other Issues

  4. Important! • When collecting free product or other HazMat samples, you need to think SMALL and inside the box! • Upon unplanned discovery of free product requiring sampling: • Stop work, • Contact laboratory to determine the minimum volume required for analysis, and • Only collect the minimal amount required. Project Managers and Task Managers Read more on this topic: DOT Facts-103a

  5. Package Selection The packaging selected depends on how you want to ship the material: • Air shipment • Ground shipment The volume of material you want to ship or transport: • Samples for analysis (small volumes) • Samples for treatability study testing (larger volumes) • IDW for disposal (large volumes – may be bulk packaging) As permitted by the DOT HMT and/or IATA LDGs • Permitted Packaging materials of construction • Inner Packaging limits • Outer Packaging limits • Also be aware of carrier packaging requirements (more on this later in the training)

  6. DOT and IATA Permitted Packagings DOT HMT Packaging Instructions IATA Packing Instructions

  7. DOT and IATA Packaging Limits DOT HMT Package Limits IATA Package Limits

  8. Example of a DOT Packing Instruction for 49 CFR 173.150, Flammable Liquid Limited Quantity • For ARCADIS purposes, the “Exceptions” column in the HMT usually means “Limited Quantity or Consumer Commodity, ORM-D”. However, the entire regulatory instruction should be reviewed for applicability to your shipment. What you see here is just an excerpt for Limited Quantity. If you follow ARCADIS Shipping Guide US-001, your Limited Quantity package should meet the “subpart B” package requirements.

  9. Example of a DOT Packing Instruction for Non-Bulk Packaging Used to Ship HazMat Above the Limited Quantity Exception • For DOT approved package materials for “fully regulated” Non-Bulk Packaging shipments, you need to look at the referenced citation for Non-Bulk Packages (column 8B). This example is for Flammable liquids, n.o.s., PG II (49 CFR 173. “202”). Refer to Exhibit 7 of the Workbook. This is not an ice chest! Note the “4H2”. Standard ice chests purchased from Wal-Mart and similar stores do not meet 4H2 Specification requirements

  10. Ciphering the Packaging Codes • You had the opportunity in the last module to review a fact sheet on UN specification codes for packagings. As you have seen in this module, there are many codes applied to both the outer packaging and inner packagings. • You must understand these codes if shipping HazMat in quantities requiring UN Specification packagings. • If you have not reviewed the fact sheet, you are encouraged to review it now: 1H2/Y1.5/30/02/USA/M0000 DOT Facts-104c 4G/Y3.4/S/02/USA/+AJ3086

  11. IATA DGR Packing Instruction Y305 • Similar to the DOT instructions, but usually easier to read, you must read the IATA Packing Instruction in its entirety. • IATA Packing instructions with a “Y” mean instructions for Limited Quantity! Workbook Exhibit 12

  12. Breakdown of the IATA Packing Instruction • The first major part of the Packing Instruction is Variations [both Country (State) and Operator (Carrier)]. These Variations contain important information, especially regarding packaging and volume/mass limitations. • The State code for the United States is “USG.” The U.S. Variations are specified in section 2.0 of the IATA DGR. Generally, you do not need to refer to the DOT HMT if using the IATA DGR because any DOT specific requirements for air transport will be provided in the “USG” Variations. • The Operator Code for FedEx is “FX” and UPS is “5X”. Their Variations are also listed in section 2 of the IATA DGR. An overview of common FedEx Variations will be provided later in this presentation.

  13. Breakdown of the IATA Packing Instruction • The second major part of the Packing Instruction is general information about applicability of the Packing Instruction and general requirements. Always review the UN numbers to see if your PSN UN Number is listed and read any qualifying criteria, if listed. • Note for this Packing Instruction – there is a maximum gross package weight (30 kg or 66 pounds).

  14. Breakdown of the IATA Packing Instruction • The third major part of the Packing Instruction is permitted packagings and volume limits for Inner Packagings (Outer Packaging volume limits are listed in the IATA LDG [column H for this Packing Instruction because its Limited Quantity]). • Note that 500ml is the maximum inner container size for all container materials listed. Look at the different types of Outer Packagings that can be used. If the name appears (i.e. Steel), you can use that packaging. In this Packing Instruction, plastic Outer Packages must be a “solid plastic box.” Also observe there are no UN Specification codes listed for the packaging (no “4H2”). Gee… what does that sound like – an ice chest!

  15. DOT and IATA Special Provisions • You need to read all of the Special Provisions applicable to your shipment. • For the DOT HMT, in general: • If the code is just a number (i.e. “8”) you should read it • For other codes with the prefix: • “A” codes apply to transportation by aircraft. • “B” codes apply to bulk packages, but generally do not apply to UN portable tanks or intermediate bulk containers (IBCs). • “IB” and “IP” codes apply to IBCs. If no code for IBCs is listed for a PSN, an IBC may not be used unless authorized by the DOT Associate Administrator. • “N” codes only apply to non-bulk packagings. • “R” codes only apply to transportation by rail. • “T” codes apply to transportation using UN portable tanks. • “TP” codes apply to transportation using IM or UN Specification portable tanks. • “W” codes apply to transportation by water … • read what is applicable to the packaging or mode of transport you are using. Odds are the Special Provision provides an exception or exemption – so read them! • Always read every IATA Special Provision!!

  16. DOT and IATA Special Provisions DOT HMT Special Provisions IATA Special Provisions

  17. Shipping Multiple HazMat in a Single Package? For air transport under IATA, you can ship multiple compatible HazMat in a single package if you compute what is known as the “Q Value” for the shipment. • For Classes other than Hazard Classes 2 and 9, the Q Value is the total net quantity of all HazMat per package where the value does not exceed “1” when calculated using the formula on the following slide…

  18. Computing the Q Value Where: n1, n2, etc. are the net quantities per package of the different hazardous materials. M1, M2, etc. are the maximum net quantities per package for these different hazardous materials (as prescribed in IATA section 4.2 LDGs or applicable section reference in 49 CFR Part 173) • The “Q” value is rounded up to the first decimal place and entered on the Shipper’s Declaration under “quantity and type of packaging” following the statement “All packed in one[insert package type] Q=X.X” • For Classes 2 and 9, when packed together other classes, the total net quantity in the package of goods other than Classes 2 and 9 does not exceed the value of 1 when calculated as above • Dry ice (UN1845) does not need to be taken into account when performing “Q” calculations

  19. You want to ship 120 ml of gasoline free product, 1 L of diesel fuel free product and 500 ml of free product containing a mixture of gasoline and diesel in a standard ice chest using Limited Quantity. Refer to Workbook Exhibit 9. Find the maximum quantity permitted for Limited Quantity (column H) for the following PSNs: “Gasoline” “Diesel fuel” “Petroleum products, n.o.s” Round up 0.72 to the first decimal place: 0.8 0.8 <1 these three samples can be shipped together in the same sample cooler under Limited Quantity. Computing the Q Value

  20. The Q Value too Complicated? The solution is simple. Avoid having to compute the Q Value by only shipping one HazMat in the package! • HazMat with the same Hazard Class, PGand Proper Shipping Name UN1203, Gasoline, 3, II//1 plastic box x 0.12 L//Y305//Ltd. Qty. No Q Value needed for this shipment! More on Documentation later……

  21. Overview of Sample Cooler Preparation Rules • The following rules apply to HazMat sample package preparation: • Only fill bottles containing HazMat liquids 90% full • This includes samples placed in VOA vials! • Tape or secure lids of all bottles • Place bottles in self sealing plastic bags • Place bottles in a secure upright position in the sample cooler • Ensure cooler has a bag liner (trash bag) containing the samples and tie off • Place absorbent materials in the cooler in case of bottle breakage • No contamination on the exterior of the cooler! The goal is making sure nothing leaks out of the cooler at any time during transport! Following ARCADIS Shipping Guide US-001 ensures requirements are met! Review the DOT and IATA regulatory requirements for package preparation for both DOT and IATA: DOT Facts-104i

  22. Using Ice Chests for Sample Shipments Standard solid plastic ice chests are acceptable for: • Unregulated samples • HazMat sample shipments if shipped under: • Excepted Quantity; or • Limited Quantity The ice chest does need to meet what DOT and IATA call Stack Test and Drop Test criteria. ARCADIS has performed these tests on a variety of ice chest types from different manufacturers. The results of these tests are located in ARCADIS Package Performance Test PT-01 located on the DOT Team Site of the APEX. When using ice chests, always use ice chests in new or like new condition for HazMat shipments. All HazMat sample shipments in ice chests must follow ARCADIS Shipping Guide US-001 requirements for cooler preparation.

  23. Stop, Think, Select! • When you sample a HazMat for shipment, work with the lab to collect volumes of material that permit you to ship the sample(s) using packaging in the following order of preference: • Ice chests or standard cardboard boxes • Special Permit Packaging or 49 CFR 173.13 Packaging • UN Specification Packaging • Your goal is to collect volumes of HazMat that will be permitted to be shipped in a standard ice chest as: • Excepted Quantity; and • Limited Quantity shipments! • While other packagings are permitted, they create additional requirements that add costs, potentially delay delivery, and increase the chance of error in preparing the shipment Are you thinking SMALL!

  24. Enough with Sample Coolers, I Want to Transport 100 Cubic Yards of PCB Impacted Sediments in Dump Trucks from an Off Site Location Back to the Client Property • Let’s say you have some drained sediments you dredged up from a river and those sediments contain 500 ppm total PCBs. The EPA is not going to require you to have a HWM to move this material back onto the client property. Through the Shipping Determination process, you have determined the Hazard Class, PG, and PSN for this material as: • UN3077, Environmentally hazardous substance, solid, n.o.s. (polychlorinated biphenyls mixture), Class 9, PG III • Refer to Workbook Exhibit 8 and find the above PSN. Now look in column 8C and note the Packing Instruction • Note: Special Provision 141 (Workbook Exhibit 8, column 7) states PG III is authorized if transported on a public roadway or by rail. Always read your Special Provisions!!!!

  25. DOT Packing Instruction 49 CFR 173.240 Lets review authorized Bulk Packagings in this Packing Instruction: Where is the dump truck? Dump trucks, roll-off boxes, etc. are considered by DOT as “Non-DOT Specification sift-proof closed vehicles” or “sift-proof closed bulk bins”

  26. How to Sift Proof a Dump Truck • Basically, you line the dump truck with plastic or specialty liners and encapsulate your PCB impacted sediment. The same holds true for roll-off boxes. Always tarp the open top for added protection of the cargo from the elements

  27. Only collect the minimal amount of free product necessary to perform required analyses. Work with the laboratory to select proper containers for free product collection Careful consideration must be given to the packaging selected to ensure your HazMat is shipped properly Always read Packing Instructions in their entirety and take the time to read Special Provisions since they may affect packaging permitted to be used The term “solid plastic box” in DOT and IATA Packing Instructions means “ice chest” to Limited Quantity ARCADIS shipments If you want to move solid HazMat by dump trucks or roll off boxes, make sure they are authorized packagings for the HazMat and make sure they are sift proof, when required Conclusions

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