Practice Makes Perfect
Most of us have heard the phrase, “Practice makes perfect”. I did when learning my multiplication tables. Others hear it in reference to playing sports. What is interesting is the phrase originates from the 1500’s. In Latin, it is ‘Uses promptos facit‘ which translates to ‘use makes mastery’. Vince Lombardi, American football player and coach, said it differently. For him, “Practice does not make perfect. Only perfect practice makes perfect” was the correct way to say it. The intent is the same. The only way to get batter at something is to practice it.
So how does that relate to making the correct packaging selection for shipments of hazardous materials? A shipper should practice using the regulation and the UN Specification Markings together before making any decisions on packaging. When working with clients in transportation training sessions I always remind participants that packaging is two-fold. You have to use what the regulations say and what the marking on your packaging allows. Let’s do a practice problem to show what I mean.
Can a shipper put 16 Liters of UN1114 Benzene into a steel drum with a non-removable head for a US Ground shipment using 49 CFR? Benzene has a specific gravity of 0.876 g/ml. The drum has the code 1A1 / Y1.8 / 250 / 16 on it.
Solving Process/Logic: First, the shipper has to understand what the specification marking means. It is a steel drum with a non-removable head single packaging for liquids. The drum is rated to hold Packing Groups II and III materials if their specific gravity measurements are 1.8 g/ml or less. The 16 Liters makes it a non-bulk shipment. This means column 8B of the Hazardous Materials Table (HMT) of 49 CFR is checked. The HMT sends the shipper to Section 173.203 for authorized packagings for that description. A steel drum with a non-removable head as a single packaging is listed in Paragraph (c).
Final Answer #1: This shipment is acceptable per the regulations and for the packaging.
Using the same setup as Problem #1, let’s change the Specification code to 3H2 / Z25 /S/ 17. Is this allowed?
Solving Process/Logic: Again, the shipper has to understand what the specification marking means. It is a plastic jerrican with a removable head. It is rated to hold Packing Group III materials only and the maximum gross mass allowed is 25 kilograms. Check the regulations to see if the shipment is allowed by 49 CFR. The full shipping description is still UN1114 Benzene Class 3 Packing Group II. At this point, the shipper can stop. The jerrican is only rated to hold Packing Group III materials. Benzene is in Packing Group II.
Final Answer #1: This shipment is acceptable per the regulations. However, it is NOT for the packaging.
These problems are not easy. Try some on your own using the materials shipped from your location and the packaging you have on hand. Remember, the only way to have your decisions be perfect is to practice.
For all your training and packaging needs, contact ICC Compliance Center today.