It is the responsibility of the container manufacturer to perform and document design qualification testing, periodic retesting and production testing in accordance with Subpart M - Testing of Non-Bulk Packagings and Packagers. Each manufacturer must certify the packaging is capable of passing the prescribed tests (§178.601(b)). All records are to be kept at each location where the packaging is manufactured and at each location where design qualification tests are conducted for as long as the packaging is produced and for at least two years thereafter. All records must be made available to the Department of Transportation upon inspection.

Each container must be manufactured and assembled so as to be capable of successfully passing the prescribed tests. The DOT secures containers randomly to determine compliance.

Container manufacturers may use a DOT approved third party testing facility to perform the design qualification and the periodic retests.

1. the location, type or size, and material of closures (other than the cover of UN 1A2 drums); and
2. for UN 1A2 drums:

1. gasket material or properties affecting the performance of the gasket;
2. configuration or dimensions of the gasket;
3. closure ring style including bolt size (e.g. square or round back, 0.625" bolt); and
4. closure ring thickness.

The design qualification test is applicable for containers shorter than the original design as long as all other construction is identical. For example, a certification for a 208 liter (55 gallon) drum is valid for a 197 liter (52 gallon) drum made on the same diameter. §178.601 (c)(4)(v).

To determine the capabilities of a container, design qualification testing is performed on the initial design type. No UN marking may appear on the container.

• Drop Test

• Stack Test

• Hydrostatic Test

• Leakproofness Test (closures in place)

• Vibration Standard *

(*§178.608 states that each packaging must be capable of withstanding the vibration test procedure.)

To ensure integrity of the design qualification test results, periodic retesting is performed on an annual basis. Each container must be embossed with the UN marking to which it is being tested.

• Drop Test

• Stack Test

• Hydrostatic Test

• Leakproofness Test (closures in place)

Must be performed on every container produced

Design Qualification and Periodic Retest
The drop test for containers to contain liquids is a vented drop, i.e. the plugs must be vented after dropping the drum to equalize the internal and external pressures. The container must be at least 98 percent full with liquid and dropped from the height determined by the packing group designation.

The drop test for containers to contain solids must be filled to at least 95 percent capacity with a material having physical properties (grain, size, viscosity) similar to the intended lading. Drop height is determined by the packing group designation.

The container is to be dropped using the orientation most likely to result in failure.

Criteria for Passing
There is no leakage of the filling substance from the drum.

Design Qualification and Periodic Retest
Containers must be tested with closures in place. Once filled with the pressure listed below, containers must be restrained under water for a minimum of five (5) minutes time to pressurize the interior of the packaging and determine if there is any air leakage from the container. Alternative methods outlined in Appendix B to Part 178 are also authorized.

Test Pressures

Criteria for Passing
There is no leakage of air from the container.

Design Qualification and Periodic Retest
Containers are filled with water and pressurized according to §178.605 (d)(1-3). Containers must be tested for a minimum of five (5) minutes.

Packing Group I must be tested to a minimum test pressure of 250 kPa (36 PSI).

Criteria for Passing
There is no leakage of liquid from the container.

Stacking Test §178.606

Design Qualification and Periodic Retest
Filled as for shipment, containers must be subjected to a force applied to the top surface of the drum for twenty-four hours equal to the total weight of identical packages which might be stacked on it during transport. Minimum stack height is three meters.

Criteria for Passing
There is no leakage of substance from the container; no distortion or deformation.