Q&A: How long must a shipper of HazMat retain testing reports of their Performance Oriented Packaging?

Q&A: How long must a shipper of HazMat retain testing reports of their Performance Oriented Packaging?

Q&A: How long must a shipper of HazMat retain testing reports of their Performance Oriented Packaging?

A question from an environmental consulting firm I work with on January 18, 2018 regarding one of their clients:

Dan,

We have a client who asked what the duration of time that was required to maintain what he called, “UN POP Testing Reports.”

I believe he is referring to package certifications which are given after the packaging meets stress test guidelines and allows the person to request the packaging be made by a container manufacturer and include the specification mark.

I may also be incorrect in that presumption. Perhaps POP is referring to Performance-Oriented Packaging and means something else.

Can you shed some light on this please? Include any regulatory reference if possible.

Thanks

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My reply that same day:

He is probably referring to the Performance Oriented Packaging standard created by the UN to test and confirm a packaging meets a specification.  USDOT specification packaging includes UN Standard which is subject to POPS.

Maintaining records depends on their function.  If they are a shipper or carrier of hazmat, the answer is none.  They are not required to obtain or maintain the test records.
Persons involved in the manufacturer, design testing, and periodic retesting of a hazmat packaging must retain records as follows (this is only for non-bulk & IBCs):
  • 49 CFR 178.601(l) for non-bulk packaging & 178.801(l) for IBC:
    • Manufacturer: as long as manufactured and two years thereafter.
    • Design testing: six years after test successfully performed. Combination packaging or for Division 6.2: seven years.
    • Periodic retesting: one year after test successfully performed.  Combination packaging or for Division 6.2:  two years.

I hope this helps.  Please contact me with any other questions.

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