The Hazardous Material Regulations of the Pipeline and Hazardous Materials Safety Administration (PHMSA, an administration within the US DOT), require all hazardous materials to be transported in authorized packaging (49 CFR 173.24(c)). Authorized packaging can be determined in only one of two ways:
- In columns 8A (packaging exceptions), 8B (non-bulk packaging), or 8C (bulk packaging) of the hazardous materials table at 49 CFR 172.101 of the HMR. Each column will indicate the section of Part 173 where authorized packaging for that HazMat is identified. “None” in any of column 8 indicates that form of packaging is not available. Further, the HazMat shipment must conform to any applicable special provisions in column 7 of the hazardous materials table (special provision codes are explained at 49 CFR 172.102). Also, if specification packaging, it must meet the requirements of parts 178 (for most packagings) and part 179 (for railroad tank cars).
Meeting the requirements of parts 178 and 179 does not apply to a UN Standard packaging that is manufactured outside of the U.S.
- The packaging is permitted under and conforms to the requirements of the U.S Bureau of Energy found at §171, subpart B or those of the applicable international agency found at §171, subpart C. Or, conforms to packing instructions found at: §173.3, §173.4, §173.4a, §173.4b, §173.5, §173.5a, §173.6, §173.7, §173.8, §173.27, or §176.11.
So, what happens when the packaging for a hazardous material is not the authorized packaging as determined by compliance the HMR? See below:
More significant because of the volume and nature of the HazMat, the lesson can be applied to smaller volumes and less hazardous materials: using a packaging that is not authorized for a hazardous material can result in package failure leading to loss of property, injury, and death.
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