The Hazardous Materials Regulations (HMR) of the USDOT/PHMSA require most packagings used for the transport in commerce of a hazardous material (HazMat) to meet a DOT specification or a UN standard. Some HazMat are subject to a packaging exception and others – though fully regulated – are allowed to be transported in other forms of specification packaging, e.g., a packaging in compliance with a special permit; these do not require DOT specification or UN standard packaging.
Most shipments of HazMat, however, will require a DOT specification or UN standard packaging. Those that are non-bulk packagings must be manufactured to a standard identified in 49 CFR 178, subpart L and be able to pass certain tests specified in §178, subpart M. One of those required tests is the leakproofness test.
What packagings must be leakproofness tested?
If a single or composite packaging is intended to contain a liquid, it is subject to the leakproofness test of 49 CFR 178.604, except under the following conditions:
- The inner receptacle of a composite packaging may be tested without the outer packaging as long as the test results are not affected.
- The test is not required for the inner packaging of a combination packaging.
Both single and composite packaging are defined at §171.8:
- Composite packaging means a packaging consisting of an outer packaging and an inner receptacle, so constructed that the inner receptacle and the outer packaging form an integral packaging. Once assembled it remains thereafter an integrated single unit; it is filled, stored, shipped and emptied as such.
- Single packaging means a non-bulk packaging other than a combination packaging.
Who is responsible for the leakproofness test?
The HMR does not indicate who must complete the leakproofness test, only who is responsible for its successful completion, i.e., “test and pass”.
- For a newly manufactured packaging, §178.601(b) makes it the responsibility of the packaging manufacturer to assure each packaging is capable of passing the prescribed tests; one of which is the leakproofness test.
- Pursuant to §173.28(c)(3), a reconditioner of a non-bulk packaing is responsible for certifying a packaging meets all of the requirements of §178, which includes – but is not limited to – the leakproofness test.
- A person who remanufactures a non-bulk packaging must comply with §173.28(d) and certify compliance with part 178 (just as if they were the packaging manufacturer), which includes – but is not limited to – the leakproofness test.
- At §173.28(b)(2), a person who intends to reuse a non-bulk packaging must ensure it is retested without failure on the leakproofness test.
If you are any of the above “persons” it is your responsibility to ensure the leakproofness test is successfully completed per §178.604. You may perform it yourself or have it performed by a 3rd party.
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How many packagings must be tested?
The number of packagings to be tested depends upon the type of testing required. Three different testing types are defined at §178.601(c) and identified below.
- Production testing is the performance of the leakproofness test on each single or composite packaging intended to contain a liquid.
- Periodic retesting is the performance of tests, as applicable (this includes the leakproofness test), at a frequency determined by the packaging manufacturer but at least annually.
- Design qualification testing is the performance of the applicable tests (including leakproofness test) for each new or different packaging at the start of its production.
For production testing, all packagings must be tested and pass prior to the following:
- First use in transportation.
- Prior to reuse, when authorized for reuse by §173.28.
- The requirements for leakproofness testing of packagings for reuse are at §173.28(b)(2).
- Interestingly, the pressure required to be applied during leakproofness testing for reuse of a packaging at §173.28(b)(2)(i) is different than the pressure requirements specified at §178.604(e) and identified later in this article.
- §173.28(b)(7) provides for an exception from leakproofness testing for certain packagings.
For design qualification and periodic testing:
- Three (3) samples of each different packaging must be tested and pass the leakproofness test.
- Exceptions for the number of samples used are allowed subject to approval of the Associate Administration (i.e., USDOT/PHMSA).
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What are the requirements for the leakproofness test?
- The leakproofness test must be performed with compressed air or other suitable gasses.
- For design qualification and periodic testing, packagings must be tested with closures in place.
- For production testing, packagings need not have closures in place.
- If tested with closures in place, vented closures must either be replaced by similar non-vented closures or the vent must be sealed.
- Removable heads need not be installed during production testing.
- The packaging must be restrained under water while an internal air pressure is applied.
- The method of restraint must not affect the results of the test.
- For design qualification and periodic testing, the test must be conducted for a minimum of five (5) minutes. A minimum test time is not specified for production testing.
- Test methods other than “restraint under water” identified above may be used in accordance with appendix B to part 178.
- Read: Quick Take: Alternatives to the Leakproofness Test Method
- You may even develop your own pressure testing machine to perform the leakproofness test if it conforms to appendix B to part 178 (01-0177).
- An internal air pressure (gauge) must be applied to the packaging as indicated for the following packing groups:
- Packing Group I: Not less than 30 kPa (4 psi). Note: the regulations for leakproofness testing of a packaging prior to reuse at §173.28(b)(2)(i) require an internal air pressure (gauge) of at least 38 kPa (7.0 psig) for Packing Group I.
- Packing Group II: Not less than 20 kPa (3 psi).
- Packing Group III: Not less than 20 kPa (3 psi).
- A packaging passes the test if there is no leakage of air from the packaging.
The leakproofness test of 178.604 is designed to ensure that a non-bulk packaging designed to be the sole containment for a liquid hazardous material can withstand the rigors of transport without rupture or other package failure that may result in a leak. Make sure your packaging has passed the leakproofness test.
Q: How will I know if my packaging has passed the leakproofness test of 178.604?
A: If the packaging is new, the DOT specification or UN standard marked on the package is the indication it has passed all the required tests. If the packaging is reconditioned, remanufactured, or reused, it must be marked with the letter “L” and other identifying information to indicate it has passed the leakproofness test.
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