While there are many different types of HazMat packaging, all of them fall into one of two categories: bulk or non-bulk. The purpose of this article is to define and explain both bulk and non-bulk packagings pursuant to the regulations of the PHMSA/USDOT.
Both bulk and non-bulk packaging are define at 49 CFR 171.8:
Bulk packaging means a packaging, other than a vessel or a barge, including a transport vehicle or freight container, in which hazardous materials are loaded with no intermediate form of containment. A Large Packaging in which hazardous materials are loaded with an intermediate form of containment, such as one or more articles or inner packagings, is also a bulk packaging. Additionally, a bulk packaging has: * * *
(1) A maximum capacity greater than 450 L (119 gallons) as a receptacle for a liquid;
(2) A maximum net mass greater than 400 kg (882 pounds) and a maximum capacity greater than 450 L (119 gallons) as a receptacle for a solid; or
(3) A water capacity greater than 454 kg (1000 pounds) as a receptacle for a gas as defined in §173.115 of this subchapter.
Non-bulk packaging means a packaging which has:
(1) A maximum capacity of 450 L (119 gallons) or less as a receptacle for a liquid;
(2) A maximum net mass of 400 kg (882 pounds) or less and a maximum capacity of 450 L (119 gallons) or less as a receptacle for a solid; or
(3) A water capacity of 454 kg (1000 pounds) or less as a receptacle for a gas as defined in §173.115 of this subchapter.
Since bulk and non-bulk packagings are both a type of packaging, its important to know that defined term as well (also at 49 CFR 171.8):
Packaging means a receptacle and any other components or materials necessary for the receptacle to perform its containment function in conformance with the minimum packing requirements of this subchapter. For radioactive materials packaging, see §173.403 of this subchapter.
So, a packaging is anything used to contain a hazardous material in transportation as long as it meets the minimum requirements of the Hazardous Material Regulations.
It is interesting to note that the definition of a bulk packaging begins by specifically excluding two items: a vessel or a barge, before specifically including – but not limiting it to – two others: a transport vehicle or freight container. In the next sentence it also includes a Large Packaging with conditions. However, the exclusion or inclusion of each packaging is not based solely on their name; a critical factor is the use of an intermediate form of containment. These conditions are summarized in Table 1.
Intermediate Form of Containment?
Can’t be a Bulk Packaging
Can be a Bulk Packaging*
*Additional conditions must be met.
The definitions of these terms from 49 CFR 171.8:
Vessel includes every description of watercraft, used or capable of being used as a means of transportation on the water.
Barge means a non-self propelled vessel.
So, any type of watercraft where the hazardous material is loaded without an intermediate form of containment – ie. where the skin of the vessel is the containment for the HazMat – can not be a bulk packaging. Why? Well, it’s because vessels of that type are regulated by the Coast Guard and are not subject to PHMSA/USDOT regulations at all.
Definitions in 49 CFR 171.8 continue:
Transport vehicle means a cargo-carrying vehicle such as an automobile, van, tractor, truck, semitrailer, tank car or rail car used for the transportation of cargo by any mode. Each cargo-carrying body (trailer, rail car, etc.) is a separate transport vehicle.
Freight container means a reusable container having a volume of 64 cubic feet or more, designed and constructed to permit being lifted with its contents intact and intended primarily for containment of packages (in unit form) during transportation.
So in this case, a transport vehicle and/or a freight container may be a bulk packaging if both of the following are true:
- The HazMat is loaded with no intermediate form of containment. In other words, the skin of the transport vehicle – such as a cargo tank motor vehicle – is the only containment for the HazMat.
- The packaging maximum capacity thresholds (see below) are met.
One final note about this portion of the definition: while a vessel and barge are clearly excluded, the definition of a bulk packaging includes – but is not limited to – a transport vehicle or freight container. This means that other HazMat packagings not identified in the definition (eg. intermediate bulk container, portable tank, rail car, &etc.) may be a bulk packaging if both of the above conditions are met.
A Large Packaging is included in the definition as a unique condition, which it is. Defined at 49 CFR 171.8:
Large packaging means a packaging that—
(1) Consists of an outer packaging that contains articles or inner packagings;
(2) Is designated for mechanical handling;
(3) Exceeds 400 kg net mass or 450 liters (118.9 gallons) capacity;
(4) Has a volume of not more than 3 cubic meters (m3) (see §178.801(i) of this subchapter); and
(5) Conforms to the requirements for the construction, testing and marking of Large Packagings as specified in subparts P and Q of part 178 of this subchapter.
So, a Large Packaging – which is basically a big metal box used to contain other HazMat packagings for transportation by vessel, highway, or rail (ie. an intermodal container) – may be a bulk packaging even if its skin is not the only containment for the HazMat and it contains one or more articles or inner packagings.
We’re not done! In addition to the above, a bulk packaging has a maximum capacity or net mass above the following thresholds:
- >450 L (119 gallons) for a liquid.
- >400 kg (882 pounds) net mass and >450 L (119 gallons) for a solid.
- A water capacity of >454 kg (1,000 pounds) for a gas (gas is defined at 49 CFR 173.115).
|The definition of a bulk packaging found on page 21 of the PHMSA guidance document: “How to Use the Hazardous Materials Regulations” is wrong! Its definition of a bulk packaging reads in part, “…400 kg (882 pounds) net mass for a solid…” It is missing the reference to the volume threshold for a solid bulk packaging found in the definition at 49 CFR 171.8.|
Quite simply, a non-bulk packaging is any packaging that does not meet the maximum capacity or net mass thresholds of a bulk packaging (there is no reference in the definition to the type of packaging):
- A maximum capacity of 450 L (119 gallons) or less as a receptacle for a liquid;
- A maximum net mass of 400 kg (882 pounds) or less and a maximum capacity of 450 L (119 gallons) or less as a receptacle for a solid; or
- A water capacity of 454 kg (1000 pounds) or less as a receptacle for a gas (gas is defined at §173.115).
If after reviewing the above you still have questions about your HazMat packaging, don’t hesitate to contact me with your questions. I’m glad to help.
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Are aerosol cans loaded in a UN specification bulk packaging, i.e. an 11G fiberboard Intermediate Bulk Container (IBC) subject to the marking, labeling and placarding requirements for a bulk packaging?
No. The definition of a bulk packaging specifies that it must contain hazardous materials that are loaded with no intermediate form of containment. The aerosol cans in the 11G box would be a form of intermediate containment and, thus, not considered a bulk packaging. It is interesting that in this situation what may start as a bulk packaging may not continue to meet the definition depending on how it is used.