If you are a shipper of hazardous materials (HazMat) you are subject to the Hazardous Materials Regulations (HMR) of the Pipeline and Hazardous Materials Safety Administration within the U.S. Department of Transportation (USDOT/PHMSA). The HMR identify a variety of packagings used for the transportation in commerce of hazardous materials. One of these packagings to be explained in this article is the large packaging.
A strange name for a packaging, “What is meant by ‘large’?” Well, thankfully, this vaguely-named packaging is clearly defined at 49 CFR 171.8 of the HMR:
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 let’s break that down…
- “…Consists of an outer packaging that contains articles or inner packagings;”
- Since it must consist of articles or inner packagings, it is not intended to come into direct contact with the the HazMat it contains. This in itself is not distinctive; the definition of combination packaging at §171.8 also indicates it consists of one or more inner packagings secured in an outer packaging.
- The definitions of two terms used in that sentence will assist with understanding:
Inner packaging means a packaging for which an outer packaging is required for transport. It does not include the inner receptacle of a composite packaging.
And…
Outer packaging means the outermost enclosure of a composite or combination packaging together with any absorbent materials, cushioning and any other components necessary to contain and protect inner receptacles or inner packagings.
Note: the HMR does not include a definition of “article” but its use by USDOT/PHMSA indicates it is similar to an inner packaging in that an outer packaging is required for its transport.
So, the articles or inner packagings within a large packaging are not by themselves acceptable for transport in commerce of hazardous materials. They must be placed in an outer packaging – in this case a large packaging – in order to be acceptable for transport.
|
Like this article? Subscribe to my Monthly Newsletter No marketing emails! |
- “Is designated for mechanical handling:” means it is designed to be moved by equipment or machinery, not a person. This implies that the large packaging will have devices, attachments, &etc. necessary for mechanical handling.
- “Exceeds 400 kg net mass or 450 liters (118.9 gallons) capacity;”
- This creates a minimum capacity limit for a large packaging with a result that it will always be a bulk packaging. You may read an earlier article I wrote about bulk packaging, but for the purpose of this article on large packaging the following text from the definition of bulk packaging is most important:
…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…
- “Has a volume of not more than 3 cubic meters (m3) (see §178.801(i) of this subchapter); and”
- This converts to approximately 4 cubic yards, 793 gallons or exactly 3,000 liters.
- This aspect of the definition is most interesting since it creates an upper limit on the capacity of the large packaging. A large packaging can not have a capacity above this value. I am not aware of any other defined packaging type that includes such a limit.
- You may disregard the reference to §178.801(i). Its inclusion in the definition of large packaging is an error. It is a leftover from previous rule-makings and should be removed. I explain my reasoning at the end of this article. If you’re interested in digging that deep into the regulations, please read what I wrote. Otherwise, take my word for it, you can disregard the reference to §178.801(i) in the definition of a large packaging.
- “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.” Perhaps the most important part of this definition since it mandates that a large packaging be designed, manufactured, and tested to meet a packaging specification and that it must be marked to indicate it meets that specification. There are two types of large packaging identification codes identified in 49 CFR 178, subparts P and Q:
- 50 for rigid large packagings
- 51 for flexible large packagings
|
Contact me with any questions you may have about the transportation of hazardous materials by air, highway, vessel, or rail International and Domestic Daniels Training Services, Inc. 815.821.1550 |
More about large packaging:
Not all of the relevant information about large packaging is found in the definition.
- A shipper of HazMat using a large packaging must comply with the packing instructions specific to a large packagings at §173.36.
- The definition of a combination packaging at §171.8 is important since it is very similar to a large packaging with one key difference (see if you can spot it):
Combination packaging means a combination of packaging, for transport purposes, consisting of one or more inner packagings secured in a non-bulk outer packaging. It does not include a composite packaging.
So, a combination packaging must be a non-bulk packaging whereas a large packaging must be a bulk packaging.
Conclusion:
Now you know the definition of a large packaging you will have to determine if you can use it. To the best of my understanding, a large packaging is the same as a combination packaging but in the form of a bulk packaging. This may make the transport of large quantities of HazMat in inner packagings or articles much easier. Just make certain a large packaging is an authorized packaging for the HazMat you intend to offer for transport.
|
I would greatly appreciate it if someone could send me images of a large packaging that I can use in this article! |
My explanation of the presence of §178.801(i) in (4) of the definition of a large packaging:
The reference to §178.801(i) in (4) of the definition of a large packaging is odd since 49 CFR 173.801(i) reads:
(i) Approval of equivalent packagings. An IBC differing from the standards in subpart N of this part, or tested using methods other than those specified in this subpart, may be used if approved by the Associate Administrator. Such IBCs must be shown to be equally effective, and testing methods used must be equivalent.
It doesn’t appear to have anything at all to do with a large packaging. And it doesn’t. Its presence in the definition of a large packaging is due to an oversight by USDOT/PHMSA when it changed its regulations years ago. If you’re interested in the history I’ve discovered, see below. Otherwise, just pretend its not there.
History:
The term large packaging was added to the HMR as part of final rule HM-215D, published in the Federal Register on June 6, 2001 (66 FR 33315). It was done to harmonize the HMR with international regulations.
We are adding four new definitions to § 171.8. “Large packaging” is added to correspond with the addition of an approval provision that allows the use of large packagings which comply with requirements in the UN Recommendations (see § 178.801(i)). Large packagings are UN-marked bulk packagings which are very similar to IBCs, with the exception that they contain inner packagings.
Notice the reference to §178.801(i) which appears in the definition of a large packaging to this day. According to the Federal Register, the original citation referred to an approval provision for the use of large packagings.
Section 178.801. In paragraph (i), we are adding an approval provision for the use of large packagings, as defined in § 171.8 of this NPRM, provided the large packagings conform to the construction standards, performance testing and packaging marking as specified in UN Recommendations.
HM-215D also created the regulation at §178.801(i) which read:
(i) * * * A large packaging, as defined in § 171.8 of this subchapter, may be used if approved by the Associate Administrator. The large packaging must conform to the construction standards, performance testing and packaging marking requirements specified in the UN Recommendations.
The original definition of large packaging effective in the regulations as of October 01, 2001 read:
Large packaging means a packaging that—
(1) Consists of an outer packaging which 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 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 the UN Recommendations.
Notice the difference in (5) from the original (just above) to the definition in use today. The original lacks a reference to the HMR where the packaging specifications for large packagings (subparts P and Q of part 178) now reside. That’s because the packaging specifications didn’t exist in the HMR at that time so USDOT/PHMSA could only refer to the UN Recommendations.
So, at the time of initial publication in 2001, the reference to §178.801(i) was correct as it referred to the UN Recommendations for the construction standards, performance testing, and packaging marking requirements for a large packaging since at that time the HMR did not contain the packaging specification for large packagings in subparts P and Q to part 178.
|
Daniels Training Services, Inc. 815.821.1550 |
But what happened to §178.801(i)?
What happened was the miscellaneous packaging amendments of HM-231 published in the Federal Register February 20, 2010, effective: October 01, 2010 (75FR 5397). While this final rule resulted in several changes to the HMR, only one of them is relevant to this discussion: the addition of subparts P and Q to part 178. Since these subparts now contain the packaging specifications for a large packaging the definition for one at §171.8 was changed:
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 as specified in § 173.36, and subparts P and Q of part 178 of this subchapter, as applicable.
In (5) the reference to the UN Recommendations was removed and subparts P and Q added. However, the reference to §178.801(i) in (4) remained.
HM-231 included a lot more than just changes to the definition of large packagings and the addition of new subparts, many specification packagings found their regulations changed by this final rule. For example, §178.801(i) was changed to read:
(i) Approval of equivalent packagings. An IBC differing from the standards in subpart N of this part, or tested using methods other than those specified in this subpart, may be used if approved by the Associate Administrator. Such IBCs must be shown to be equally effective, and testing methods used must be equivalent.
Which is how it reads to this day.
What happened – to the best of my understanding – is that while the reference to §178.801(i) in HM-215D was correct, changes to the HMR made by HM-231 made the reference invalid; it should be removed from the definition but USDOT/PHMSA appears to have missed it.
| Please let me know if you disagree with me. I’d like to hear from you! |