Transcript Module 6: Packaging

Module 7: Packaging
Package Selection
General Packaging Requirements
Using Ice Chests for Sample Shipments
VS.
Imagine the result
IMPORTANT – READ
Comprehensive revisions to the hazardous materials shipping
regulations take affect on January 1, 2011. As a result of these changes,
this entire training program will be replaced on January 1, 2011.
YOU MUST COMPLETE THIS TRAINING BY MIDNIGHT
DECEMBER 31, 2010 OR YOU WILL BE REQUIRED TO REENROLL IN THIS TRAINING AND START OVER!
If you complete this training this year, you will have completed your
training obligation and you will not be required to repeat this training until
your training is up for renewal 2 years from the date of completion.
If you believe you cannot complete this training by the end of 2010,
please contact the ARCADIS Training Center to cancel your enrollment.
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Introduction
Now that you have reviewed packaging terms
and types of packagings, in this module you
will learn about package selection, using
Packing Instructions and general packaging
requirements.
You will also learn about when it is appropriate
to ship hazardous materials in a standard ice
chest.
Finally, you are going to learn how to sift proof
a dump truck. Big fun awaits you in this
module!
Imagine the result
Classification
Identification
Packaging
Marking, Labeling and
Placarding
Documentation
Exceptions and
Limitations
Other Issues
Important!
When collecting free product or other HazMat samples, you need
to think SMALL and inside the box!
Upon unplanned discovery of free product requiring sampling:
• Stop work,
• Contact laboratory to determine the minimum volume
required for analysis, and
• Only collect the minimal amount required.
Project Managers and Task Managers
Read more on this topic:
DOT Facts-103a
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Package Selection
The packaging selected depends on how you want to ship the
material:
• Air shipment
• Ground shipment
The volume of material you want to ship or transport:
• Samples for analysis (small volumes)
• Samples for treatability study testing (larger volumes)
• IDW for disposal (large volumes – may be bulk packaging)
As permitted by the DOT HMT and/or IATA LDGs
• Permitted Packaging materials of construction
• Inner Packaging limits
• Outer Packaging limits
• Also be aware of carrier packaging requirements (more on this later in the
training)
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DOT and IATA Permitted Packagings
DOT HMT Packaging Instructions
IATA Packing Instructions
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DOT and IATA Packaging Limits
DOT HMT Package Limits
IATA Package Limits
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Example of a DOT Packing Instruction for 49 CFR 173.150, Flammable
Liquid Limited Quantity
For ARCADIS purposes, the “Exceptions” column in
the HMT usually means “Limited Quantity or
Consumer Commodity, ORM-D”. However, the entire
regulatory instruction should be reviewed for
applicability to your shipment. What you see here is
just an excerpt for Limited Quantity. If you follow
ARCADIS Shipping Guide US-001, your Limited
Quantity package should meet the “subpart B”
package requirements.
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Example of a DOT Packing Instruction for Non-Bulk Packaging Used to
Ship HazMat Above the Limited Quantity Exception
For DOT approved package materials for “fully regulated” Non-Bulk Packaging
shipments, you need to look at the referenced citation for Non-Bulk Packages
(column 8B). This example is for Flammable liquids, n.o.s., PG II (49 CFR 173.
“202”). Refer to Exhibit 7 of the Workbook.
This is not an ice chest! Note the
“4H2”. Standard ice chests purchased
from Wal-Mart and similar stores do
not meet 4H2 Specification
requirements
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Ciphering the
Packaging
Codes
1H2/Y1.5/30/02/USA/M0000
4G/Y3.4/S/02/USA/+AJ3086
You had the opportunity in the last module to
review a fact sheet on UN specification codes
for packagings. As you have seen in this
module, there are many codes applied to both
the outer packaging and inner packagings.
You must understand these codes if shipping
HazMat in quantities requiring UN Specification
packagings.
If you have not reviewed the fact sheet, you are
encouraged to review it now:
DOT Facts-104c
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IATA DGR Packing
Instruction Y305
Similar to the DOT
instructions, but usually
easier to read, you must
read the IATA Packing
Instruction in its entirety.
IATA Packing instructions
with a “Y” mean
instructions for Limited
Quantity!
Workbook Exhibit 12
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Breakdown of the IATA Packing Instruction
The first major part of the Packing Instruction is Variations [both
Country (State) and Operator (Carrier)]. These Variations contain
important information, especially regarding packaging and
volume/mass limitations.
The State code for the United States is “USG.” The U.S. Variations
are specified in section 2.0 of the IATA DGR. Generally, you do not
need to refer to the DOT HMT if using the IATA DGR because any DOT
specific requirements for air transport will be provided in the “USG”
Variations.
The Operator Code for FedEx is “FX” and UPS is “5X”. Their
Variations are also listed in section 2 of the IATA DGR. An overview
of common FedEx Variations will be provided later in this
presentation.
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Breakdown of the IATA Packing Instruction
The second major part of the Packing Instruction is general
information about applicability of the Packing Instruction and general
requirements. Always review the UN numbers to see if your PSN UN
Number is listed and read any qualifying criteria, if listed.
Note for this Packing Instruction – there is a maximum gross package
weight (30 kg or 66 pounds).
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Breakdown of the IATA Packing Instruction
The third major part of the Packing Instruction is permitted
packagings and volume limits for Inner Packagings (Outer Packaging
volume limits are listed in the IATA LDG [column H for this Packing
Instruction because its Limited Quantity]).
Note that 500ml is the maximum inner container size for all container
materials listed. Look at the different types of Outer Packagings that
can be used. If the name appears (i.e. Steel), you can use that
packaging. In this Packing Instruction, plastic Outer Packages must
be a “solid plastic box.” Also observe there are no UN Specification
codes listed for the packaging (no “4H2”). Gee… what does that
sound like – an ice chest!
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DOT and IATA Special Provisions
You need to read all of the Special Provisions applicable to your shipment.
For the DOT HMT, in general:
• If the code is just a number (i.e. “8”) you should read it
• For other codes with the prefix:
–
–
–
“A” codes apply to transportation by aircraft.
“B” codes apply to bulk packages, but generally do not apply to UN portable tanks or intermediate bulk
containers (IBCs).
“IB” and “IP” codes apply to IBCs. If no code for IBCs is listed for a PSN, an IBC may not be used unless
authorized by the DOT Associate Administrator.
“N” codes only apply to non-bulk packagings.
–
–
–
–
“R” codes only apply to transportation by rail.
“T” codes apply to transportation using UN portable tanks.
“TP” codes apply to transportation using IM or UN Specification portable tanks.
“W” codes apply to transportation by water …
–
read what is applicable to the packaging or mode of transport you are
using. Odds are the Special Provision provides an exception or
exemption – so read them!
Always read every IATA Special Provision!!
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DOT and IATA Special Provisions
DOT HMT Special Provisions
IATA Special Provisions
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Shipping Multiple HazMat in a Single
Package?
For air transport under IATA, you can ship multiple compatible
HazMat in a single package if you compute what is known as
the “Q Value” for the shipment.
For Classes other than Hazard Classes 2 and 9, the Q Value is the total
net quantity of all HazMat per package where the value does not exceed
“1” when calculated using the formula on the following slide…
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Computing the Q Value
Where:
n1, n2, etc. are the net quantities per package of the different hazardous
materials.
M1, M2, etc. are the maximum net quantities per package for these different
hazardous materials (as prescribed in IATA section 4.2 LDGs or applicable
section reference in 49 CFR Part 173)
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•
The “Q” value is rounded up to the first decimal place and entered on the
Shipper’s Declaration under “quantity and type of packaging” following the
statement “All packed in one[insert package type] Q=X.X”
•
For Classes 2 and 9, when packed together other classes, the total net
quantity in the package of goods other than Classes 2 and 9 does not exceed
the value of 1 when calculated as above
•
Dry ice (UN1845) does not need to be taken into account when performing
“Q” calculations
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Computing the Q Value
You want to ship 120 ml of gasoline free product, 1 L of diesel fuel free
product and 500 ml of free product containing a mixture of gasoline and
diesel in a standard ice chest using Limited Quantity.
Refer to Workbook Exhibit 9. Find the maximum quantity permitted for
Limited Quantity (column H) for the following PSNs:
“Gasoline”
“Diesel fuel”
Round up 0.72 to the first decimal place:
“Petroleum products, n.o.s”
0.8
0.8 <1 these three samples can be shipped together in the same sample
cooler under Limited Quantity.
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The Q Value too Complicated?
The solution is simple.
Avoid having to compute the Q Value by only shipping one
HazMat in the package!
•
HazMat with the same Hazard Class, PG and Proper Shipping
Name
UN1203, Gasoline, 3, II//1 plastic box x 0.12 L//Y305//Ltd. Qty.
No Q Value needed for this shipment!
More on Documentation later……
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Overview of
Sample Cooler
Preparation
Rules
The goal is making sure
nothing leaks out of the
cooler at any time during
transport!
Following ARCADIS
Shipping Guide US-001
ensures requirements
are met!
The following rules apply to HazMat sample package
preparation:
• Only fill bottles containing HazMat liquids 90% full
•
This includes samples placed in VOA vials!
• Tape or secure lids of all bottles
• Place bottles in self sealing plastic bags
• Place bottles in a secure upright position in the
sample cooler
• Ensure cooler has a bag liner (trash bag)
containing the samples and tie off
• Place absorbent materials in the cooler in case of
bottle breakage
• No contamination on the exterior of the cooler!
Review the DOT and IATA regulatory requirements
for package preparation for both DOT and IATA:
DOT Facts-104i
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Using Ice Chests for Sample Shipments
Standard solid plastic ice chests are acceptable for:
•
Unregulated samples
•
HazMat sample shipments if shipped under:
•
Excepted Quantity; or
•
Limited Quantity
The ice chest does need to meet what DOT and
IATA call Stack Test and Drop Test criteria.
ARCADIS has performed these tests on a variety of
ice chest types from different manufacturers. The
results of these tests are located in ARCADIS
Package Performance Test PT-01 located on the
DOT Team Site of the APEX.
When using ice chests, always use ice chests in new
or like new condition for HazMat shipments.
All HazMat sample shipments in ice chests must
follow ARCADIS Shipping Guide US-001
requirements for cooler preparation.
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Stop, Think,
Select!
When you sample a HazMat for shipment, work with
the lab to collect volumes of material that permit you
to ship the sample(s) using packaging in the
following order of preference:
1.
Ice chests or standard cardboard boxes
2.
Special Permit Packaging or 49 CFR 173.13
Packaging
3.
UN Specification Packaging
Your goal is to collect volumes of HazMat that will be
permitted to be shipped in a standard ice chest as:
Are you thinking
SMALL!
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•
Excepted Quantity; and
•
Limited Quantity shipments!
While other packagings are permitted, they create
additional requirements that add costs, potentially
delay delivery, and increase the chance of error in
preparing the shipment
Enough with Sample Coolers, I Want to Transport 100 Cubic Yards of
PCB Impacted Sediments in Dump Trucks from an Off Site Location
Back to the Client Property
Let’s say you have some drained sediments you dredged up
from a river and those sediments contain 500 ppm total
PCBs. The EPA is not going to require you to have a HWM
to move this material back onto the client property. Through
the Shipping Determination process, you have determined
the Hazard Class, PG, and PSN for this material as:
UN3077, Environmentally hazardous substance, solid, n.o.s.
(polychlorinated biphenyls mixture), Class 9, PG III
Refer to Workbook Exhibit 8 and find the above PSN. Now
look in column 8C and note the Packing Instruction
Note: Special Provision 141 (Workbook Exhibit 8, column 7) states PG III is authorized
if transported on a public roadway or by rail. Always read your Special Provisions!!!!
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DOT Packing Instruction 49 CFR 173.240
Lets review authorized Bulk Packagings in this
Packing Instruction:
Where is the dump truck?
Dump trucks, roll-off boxes,
etc. are considered by DOT
as “Non-DOT Specification
sift-proof closed vehicles”
or “sift-proof closed bulk
bins”
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How to Sift Proof a Dump Truck
Basically, you line the dump truck with plastic or
specialty liners and encapsulate your PCB impacted
sediment. The same holds true for roll-off boxes.
Always tarp the open top for added protection of the
cargo from the elements
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Conclusions
• Only collect the minimal amount of free product necessary to
perform required analyses. Work with the laboratory to select
proper containers for free product collection
• Careful consideration must be given to the packaging selected to
ensure your HazMat is shipped properly
• Always read Packing Instructions in their entirety and take the
time to read Special Provisions since they may affect packaging
permitted to be used
• The term “solid plastic box” in DOT and IATA Packing
Instructions means “ice chest” to Limited Quantity ARCADIS
shipments
• If you want to move solid HazMat by dump trucks or roll off
boxes, make sure they are authorized packagings for the
HazMat and make sure they are sift proof, when required
Imagine the result