combination packaging

Q&A: What hazard communication is required on a combination packaging of isopropyl alcohol?

A question, June 08, 2020:

Good morning Daniel,

We are planning to package and ship 1 gallon contains of Isopropyl alcohol 70% in boxes of 4 gallons per box.

We plan to mark the box with a label that describes the contents and the  4” flammable placard.

As long as the UN code (UN1219, Isopropyl alcohol, 3, PGII) and the  flammable pictogram are on the on the market label,  will this meet Dot regulations?

I appreciate your assistance.

Daniels Training Services, Inc.

815.821.1550

Info@DanielsTraining.com

https://www.danielstraining.com/
It took me a week, but by June 15th I had a reply:

Thank you for contacting me. Please see below.

  • What you describe will meet the package mark & labeling requirements of USDOT/PHMSA. (A picture would be helpful).
  • However, there is more to the USDOT/PHMSA Hazardous Materials Regulations:
    • The packaging must be authorized by the regulations as indicated in column 8B of the Hazardous Materials Table, meet the DOT specification (i.e., UN Standard), and be closed per the closure instructions provided by the packaging manufacturer.
    • Class 3 HazMat label (not placard) must be displayed on the package.
    • ID # (12 mm high) & proper shipping name must be displayed as marks on the package.
    • Name of shipper or receiver marked on package.
    • Orientation arrows must be displayed on two opposite vertical sides of package.
    • Shipping paper which includes:
      • HazMat’s basic description
      • Total quantity of HazMat
      • Number and type of packaging
      • Emergency information
      • Shipper’s certification
    • Placards for Class 3 Flammable Liquid must be displayed on all four sides of the transport vehicle if the weight of the HazMat is more than (454 kg) 1,001 lbs.

And…

    • HazMat Employee training (initial & triennial) must be provided to any person with a direct affect on its safe transportation.
  • Pictogram and description of contents are requirements of OSHA and not USDOT/PHMSA.

I left a vmail message as well. Please contact me with any other questions.

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June 15, 2020. Satisfied with the answer:

Thanks for the information, Daniel.

Conclusion:

Often the questions I receive apply to only one aspect of the regulations. Not knowing the questioners level of knowledge of the Hazardous Materials Regulations I try to inform them of all of their responsibilities. It’s a lot to learn, remember, and keep straight. Periodic high-quality training (mine!) can help. My USDOT/PHMSA HazMat Employee training webinars are live, interactive, monthly, done in three (3) hours, and only $189/trainee.

Q&A: Do I Describe the Inner Receptacle of a Combination Packaging on the Shipper’s Declaration for Dangerous Goods?

Q&A: Do I Describe the Inner Receptacle of a Combination Packaging on the Shipper’s Declaration for Dangerous Goods?

A question from an attendee of my Onsite Training (12.01.16):

Hello Daniel,The question is: On the DGD is it proper to put the outer packaging in the Quantity and type of packaging column.  (This is how we have been filling it out since you trained us with no problems from any shipping company)

The forwarder is stating it should say Plastic (Which in the inner packaging) instead of Fiberboard Box (Which is the outer packaging).

Thank you!

I got right on it and had to return to her for some clarification (12.01.16):

I am researching an answer.

Can you provide a description – or a picture – of what the package in question looks like?
  • Is it two fiberboard boxes inside a third fiberboard box that makes the outer packaging?
  • Or is it two plastic inner receptacles inside a fiberboard box?
  • Or something else?

Please advise.

Her reply the next day (12.02.16):
It is nine plastic inner receptacles inside a fiberboard box.

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

Info@DanielsTraining.com

https://www.danielstraining.com/
I had a reply ready by December 5th:

I have an answer for you, thank you for your patience.  Please see below.

  • For all packed in one there is no requirement to describe the inner packagings.
  • All that is required is to show the net quantity of each of the different dangerous goods in the packaging followed by the statement “all packed in one (type of packaging)” and then the Q value.
  • Some examples of this are shown in the IATA Dangerous Goods Regulations:  Figure 8.1.G and Figure 8.1.H.
    Page of the IATA Dangerous Goods Regulations

    Figure 8.1.G and Figure 8.1.H.

This matches the overall intent of the DGR when describing dangerous goods on the Shipper’s Declaration for Dangerous Goods:  To describe the packages one will see when viewing the consignment, i.e. the outer packagings, and not the inner packagings or receptacles.

I hope this helps.  Please don’t hesitate to contact me with any questions.

That did it!

Thank you!

The transportation of dangerous goods (aka: HazMat) requires initial training before performing a regulated function and new training within 24 months (i.e. biennial).  Please don’t hesitate to contact me if you require this training or if you just have a question.  I’m here to help.