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Performance Oriented
Packaging
Background
For over forty years, the Department of
Transportation used a specification based regulations system that had become routine for
packagers of hazardous materials. Terms such as DOT 17H and DOT 17E indicated to
manufacturers how to construct and test a container.
As the world moves toward a global economy, barriers to free trade
are being eliminated. The Performance-Oriented Packaging standards embodied in the
DOT’s Hazardous Material Regulations (HMR) are based on an international system
developed in the United Nations with the purpose to promote harmonization in hazardous
materials regulations worldwide, thereby reducing obstacles to the free flow of commerce.
Countries that operate under this international system are not obligated to, but attempt
to, adopt these standard into their national regulations with as little change as
possible. Yet, differences among nations do exist and must be monitored.
All phases of hazardous materials shipment are subject to change.
This includes: packaging specification, placarding, labeling, manifesting and employee
training.
UN Recommendations on the Transport of Dangerous Goods
"Orange Book"
Developed by the Committee of Experts on the Transport of Dangerous
Goods under the authority of the UN’s Economic and Social Council, the UN
Recommendations are the basis for the U.S. regulations on the transport of hazardous
materials by air, ocean vessel, rail, road carrier or intermodal. The Recommendations,
authorized in 1957, are revised every two years and are presently formatted as Model
Regulations.
Hazardous Materials Transportation Act of 1974
The legislative authority for the U.S. Department of Transportation
in the area of hazardous materials regulations. It is usually reauthorized every three
years.
Title 49, Parts 100-199, Code of Federal Regulations
The body of regulations administered by the Research and Special
Programs Administration of the DOT. The Hazardous Materials Regulations are found in Parts
171 – 180. Part 171 is general information, Part 172 is the hazardous materials
tables and communications regulations, Part 173 general requirements for shippers and
packagings, and Part 178 packaging specifications. Title 49 is revised every October 1.
HM-181
On December 19, 1990 the United States published its final rule in
Docket No. HM-181 which adopted UN standards for the packaging a shipping of hazardous
materials developed by the UN Committee of Experts in the sixth revision of the UN Orange
Book. For the most part, the UN Orange Book recommendations were accepted by the DOT.
Several significant changes did appear in the US DOT version due to practices that applied
specifically to the United States (i.e. minimum steel thickness requirements,
reconditioning provisions, etc.). Certain thickness marking requirements were phased out
by HM-215A.
HM-215A
On December 29, 1994 the DOT published its final rule in Docket No.
HM-215A, which updated the HM-181 final rule to reflect changes made in the Seventh and
Eighth Revised Editions of the UN Orange Book. On May 18, 1995, editorial corrections were
made to HM-215A. Provisions for this rule were effective October 1, 1996.
HM-215B and HM-181H
On May 6, 1997, and September 26, 1996, DOT issued final rules for
Dockets HM-215B and HM-181H, respectively. For steel drum users, these primarily affected
provisions on salvage drums, minimum thickness, certain transitional provisions, and
design type variations. These provisions are included herein.
Old System - Specification
Based Packaging
Performance Oriented
Packaging
The new hazardous materials regulations
are based on performance oriented packaging. A container can be manufactured in any
fashion as long as the resulting package successfully conforms to the test provisions
located in §178.600.
 1A1/Y1.8/300/00
The following items are not specified under the regulations:
Capacity
Steel thickness
Height or diameter requirement
Closures
Major Changes
Shipping Papers §172.200
Markings §172.300
Labeling §172.400
Placarding §172.500
Emergency Response §172.600
Training §172.700
Shipper's Responsibilities §173.00
Manufacturer's Responsibilities §178.00
Hazmat Definitions §171.8
Hazmat Table §172.101
Non-Bulk Packaging
Containers containing less than 119 gallons or
452 Liters
Maximum Net Mass
The filler is not allowed to exceed 400 kilograms or 880 lbs into
any non-bulk packaging.
Hazardous Materials Employee (Hazmat Employee)
Anyone that during the course of their duties can effect the safe
transportation of hazardous materials through the community. This would include drum
fillers, labels, truckdrivers, manifest preparation, etc.
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