Dangerous Goods Training: Can I Use UN Specification Packaging Even When the Regulations Don’t Require It?
Our students ask this question often and in many forms. Usually it goes something like this… “I want to ship a material that does not require UN Specification packaging. I need a drum. All I have are UN specification drums. Can I use them for this?” Our dangerous goods training professionals explain:
So- Can it Be Used?
PHMSA has voiced opinions on this topic a lot in recent years. The answer is that UN Specification packaging may be used for shipments of non-regulated materials or materials that are dangerous goods but do not require UN Specification packaging. However, 49 CFR 171.2(g) says that no one may represent or offer packaging as meeting the requirements of the hazardous material regulations (HMR). Dangerous goods training will explain that this is true unless the packaging is manufactured, fabricated, marked, maintained, reconditioned, repaired, and retested in line with all applicable requirements of the HMR. This applies whether or not you use the packaging to ship dangerous goods.
What does this mean? It is best to cover the UN Specification mark when using the package when you ship non-regulated material. That is unless you can maintain the packaging. This means preventing damage that may affect the ability of passing required UN Specification testing and periodic retesting of the packaging,
There are other reasons to cover UN specification markings when a UN Specification packaging is not required. This is especially true for air carriers. For some carriers, the UN Specification marking is a sign of non-declared dangerous goods. This could cause shipment delays as the carrier finds out what’s inside the package. In some cases the package returns to the shipper as the carrier does not have the resources to verify the contents.
Finally, let’s talk about money. UN Specification packaging is often more pricey than its non-tested counterparts. Shippers can buy packaging similar to the UN Specification packaging at a much lower price.
What Are Some Best Practices?
There may be times when a UN Specification packaging is all that is on hand for a non-regulated shipment that needs to go out. In this case use what you have, but fully cover the UN Specification marking.
In general, it’s best to keep package options for both regulated and non-regulated items in stock. This lowers the chance of problems when shipping your products.
Learn more about UN Specification Packaging with Online Dangerous Goods Training
Hazmat University offers a full line of online dangerous goods training courses taught by industry pros. Want to learn more? Call us at (844) 329-5618. You can also visit our contact page. Our team will help you be confident, be competent, and be compliant through dangerous goods training.
