Variation packaging cushioning material, excepted quantity packaging, UN packaging testing, distributor deadlines for WHMIS 2015, Mexico GHS, and compatibility
Welcome back to the Regulatory Helpdesk where we answer your dangerous goods & hazmat questions. We’re here to help you become independent with – and understand the whys and hows – of the regulations.
Variation Packaging (4GV) Cushioning Material
- Q. Can I substitute a different cushioning material in a variation box?
- A. In general: “No.” When a UN-standardized package is specified. The various regulations (49 CFR, IATA DGR, IMDG Code, and TDGR), or the standards referenced within them, restrict the user to assembling the package according to the manufacturer’s instructions. These instructions are based on the components used in the submitted test/design reports on which the approval is based. 49 CFR §178.601(g)(4)(iv) even goes to the point of specifically requiring the same type of cushioning as was used in the submission.
Excepted Quantity Packaging
- Q. Is it always necessary for the shipper to have performance test results on packaging used to ship “excepted quantities”?
- A. This depends on the mode or jurisdiction of transport. 49 CFR [§173.4a(f)], IATA DGR (§2.6.6) and IMDG Code (§3.5.3) all require that the shipper ensure that testing has been done and documented. This doesn’t need to be externally certified or approved. TDGR [§1.17.1(3)] does not require specific testing, only that packaging is “… designed, constructed, filled, Continue Reading…