A question received February 01, 2018:

Hello Daniel,

I am contacting you with a question on the bulk/non-bulk classification. I work for a company that ships explosives in fiberboard drums. These drums hold no more then 100lbs but they are shipped in a tractor trailer unit that can hold up to 42,000 lbs. I am not sure if this is a bulk packaging with the fiberboard drums being an intermediate container or if it is considered non-bulk packaging because the only amount that is considered is the amount put in one fiberboard drum.

Any help on this matter would be great!

Best Regards,

My reply February 12, 2018:

Thank you for contacting me. Please see below.

• The packaging you describe (fiberboard drums of no more than 100 lbs) are a non-bulk packaging. They do not meet the definition of a bulk packaging. Read: Bulk Packaging for HazMat Explained!
• The tractor trailer unit is the transport vehicle – more specifically: the motor vehicle since it is used for transportation by highway – for the HazMat packagings. It is not a bulk packaging.
• The only type of bulk packaging that contains an intermediate form of packaging is the large packaging which is not what you describe.

I hope this helps. Please don’t hesitate to contact me with any questions. I have provided training and consulting services for others in the ordnance/explosives industry in the past.