Inland Paperboard and Packaging, Inc — Hazardous Materials Safety Interpretation

Page 1- F.. U.S. Department of Transportation 400 Seventh St., S.W. Washington, D.C. 20590 Research and Special Programs JUL 1 1 2002 Administration Mr. John H. Rutherford Reference No.: 02-0124 Manager, Testing Solutions Lab Inland Paperboard and Packaging, Inc. 8501 Moller Road Indianapolis, IN 46268 Dear Mr. Rutherford: This is in response to your letter requesting clarification of selective testing Variation 2 under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Your customer has asked you to test and certify a combination package where the inner packagings are plastic bottles containing liquids as a Variation 2 packaging. Your customer has interpreted § 178.601(g)(2)(i) to mean that glass is an example of a "fragile inner packaging." Your questions are paraphrased and answered as follows: Q1. Is it permissible to use plastic inner receptacles conditioned to -18 °C (0 °F) in lieu of glass for the drop test required in § 178.601(g)(2)(i)? Al. The answer is yes. Drop testing of combination packagings with plastic inner packagings intended to contain liquids must be carried out when the temperature of the test sample and its contents has been reduced to - 18 °C (0 °F) (see § 178.603(c). Q2. Can we certify our combination packagings for Variation 2 using plastic inner packagings? A2. The answer is yes, provided the specific conditions of the variation are met. Q3. Assuming we can test to Variation 2, should a statement be included in the certification report that the packaging qualifies under § 178.601(g)(2) for selective testing of combination packagings as long as no inner packagings more fragile than plastic at - 18 °C (O °F) are used? A3. Such a statement is permissible, but not required. Variation 2 allows inner packagings of any type in an outer packaging without retesting if the specific conditions of the variation are met.#

Page 2I hope this information is helpful. If you have further questions, please do not hesitate to contact this office. Sincerely, Hothes. Mitchet Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards#

Page 3: • of Transportation U.S. Department 400 Seventh St., S.W. Research and MAY 20 2003 Washington, D.C. 20590 Special Programs Administration Mr. John Rutherford Manager, Testing Solutions Lab Reference No.: 02-0124 Inland Paperboard and Packaging, Inc. 8501 Moller Road Indianapolis, IN 46268 Dear Mr. Rutherford: This letter replaces our July 11, 2002 response to your request for a clarification of selective testing, Variation 2, under § 178.601(g)(2)(i) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Variation 2 allows inner packagings of any type in an outer packaging without retesting if the specific conditions of the variation are met. You stated that your customer asked you to test and certify a combination package where the inner packagings are plastic bottles containing liquids as a Variation 2 packaging. Variation 2 states that the outer packaging must be tested "with fragile (e.g. glass) inner packagings containing liquids." Our responses to your paraphrased questions are as follows: Q1. Is it permissible to use plastic inner receptacles conditioned to -18 °C (0 °F) in lieu of glass for the drop test required in § 178.601(g)(2)(i)? A1. Under the HMR, the drop test required in § 178.601(g)(2)(i) may be conducted using inner receptacles made of "fragile" plastic material. The intent of Variation 2 is to conduct the test with the most fragile inner packaging. Drop testing of combination packagings with plastic inner packagings intended to contain liquids must be carried out when the temperature of the test sample and its contents have been reduced to - 18 °C (0 °F) (see § 178.603(c)). However, you should be aware that some Competent Authorities deem only glass as fragile. A proposal, ISO 16104:2002(E), currently before the United Nation's Committee of Experts on the Transport of Dangerous Goods would require the inner packagings for "v" marked packagings to be of glass, porcelain, or stoneware. If approved by the United Nations, we may propose a revision to the requirements in § 178.601(g)(2)(i) of the HMR to make them consistent with the international regulations.#

Page 4Q2. Can we certify our combination packagings for Variation 2 using plastic inner packagings? A2. The answer is yes, provided the specific conditions of the variation are met, including the use of a plastic inner packaging that is considered to be "fragile." Q3. Assuming we can test to Variation 2, should a statement be included in the certification report that the packaging qualifies under § 178.601(g)(2) for selective testing of °C (0 °F) are used? combination packagings as long as no inner packagings more fragile than plastic at -18 Such a statement is not required under the HMR, but we recommend that the Notification required by § 178.2(c) inform distributors and users of the type of inner packagings used in the certification test and advise that inner packagings that are more fragile may not be used. I hope this information is helpful. If you have further questions, please do not hesitate to contact this office. Sincerely, Hottie z. Mithell Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards#

Page 5: Apr-22-03 10:15 packg Res 6104369422 P.02 package is simply an extension of the origi- retaining its identity as one authorized and nal import movement, with the package § 171.12(b) in conformance with IMDG Code requirements, or as a foreign-manu- Letter dated July 11, 2002 to used under the § 171.12(b) IMDG Code factured package authorized for use within Mr. John H. Rutherford, import provisions. Thus, the packaging is. the United States under § 173.24(d), the Testing Solutions Lab. not being "reused" (i.e., used more than package would be required to be reclosed in once) - the return can be viewed a continu- such a manner as to conform to the manner I find DOT's responses in this letter quite port cycle for the package. So, in this regard ation, indeed, the completion, of the trans- in which the packagings subjected to the UN curious. Having worked very closely in design qualification tests were closed. It 1990 at the United Nations Committee with the DOT letter is quite correct - not with- remains unclear whether, or how, this infor- the then-DOT International Standards standing what might initially be viewed as a mation is to be provided to the customer Coordinator when what is now "Variation possible inconsistency in terms of the con- closing the package for return to Germany. i 2" in $ 178.601 (g) was first developed and ditions imposed under § 171.12(b) (6). One final comment. While the forgoing j tions, 1 recall rather cicarly that the intent of incorporated into the UN Recommenda- At the same time, however, it is unclear discussion is offered in the context of the why DOT states that the requirement in IMDG Code "import" provisions appearing these provisions was to use glass or some- the packaging is subsequently returned to 5s 173.24 and 173.24a would apply only if in § 171.12 (b), much of it would be equal- • thing of similar fragility for the design qual- ly applicable to UN packagings transported ification tests for "V-marked" packages. In would appear to apply equally either to any the United States - as these requirements under the ICAO Technical Instructions pur- glass! fact, I would say not just glass, but fragile § 171.11 differs from § 171.12(b) in that it suant to § 171.11. Interestingly, however, § 171.12(b), or to any foreign-manufac- package exported under the provisions of marked packaging was that it could be used The fundamental underlying the V- does not impose as a condition that pack- under the provisions of § 173.24(d). tured and marked UN packaging used ages being exported must comply with the design qualification tests and packaging with any inner packaging because the applicable requirements in §$ 173.24. and not addressed by DOT in its response, An issue not raised by the questioner, 173.24a and 173.28. quantity and thickness of absorbent mater- configuration (for example, in terms of is relevant to the scenario described. This Selective Testing of Variation 2 ial) demanded a very high level of perfor- concerns the manner in which the package, mance. For example, as far as the tests tomer for return to Germany. Whether after being emptied, is reclosed by the cus- Packaging • had to be used and with the drop always were concerned, fragile inner packagings shipped for return under the provisions of Reference $178.601, from the Packing Group I drop height and found on page 53 of this issue. -- • that which would be authorized for use in with the mass of inner packagings twice gh Package and v-gh Product Testing and Consulting, Inc. • Vibration = Impact shock • Compression ISO 17025 accredited* • Material analysis/testing Engineers & Technicians have been IATA trained and tested • Environmental Conditioning Evaluate and Certify Package • Video Conferencing, Product Performance Services High Speed Video Pendulum Impact Tester, I.S.T.A. (all projects), ASTM, NMFC, U.N./D.O.T Hazmat). Products up to 8000 Ibs. tested GSA, Fed & Mil Spec Testing EASTERN FACILITY * WESTERN FACILITY (513) 870-0080 (623) 869-8008 Fax: (513) 870-3017 Email: info@ghtesting.com 325 Commercial Dr., Fairlield, OH 45014 335 W. Melinda Lane, Phoenix, AZ 85027 Fax: (623) 869-8003 Email: info @ghtesting.com September/October 2002 Copyright 2002 Packaging Research International, Inc. • 877-429-7447 • Reproduction Prohibited HAZMAT Paciager & Shipper 19#

Page 6Apr-22-03 10:15 packg. Res 6104369422 P.03 the field. It would appear that use of plastic sequenty, packagings manufactured from aging design qualification tests, and, con- inner packagings to qualify a V-marked package could seriously undermine this that fibreboard considered to be of a "dif HAZMAT the plastic inner packagings, used when underlying philosophy - unless, of course, ferent design type. DOT has typically held that the fibreboard must be "virtually iden- conditioned to -18°C, become more fragile tical" - but what, exactly does that mean? Packager i Shipper than glass! or another on that issue. In the first (to Mr. Each of these letters touches in one way Moreover, the statement - which DOT acknowledges is "permissible, but not DOT states that fibreboard with a basis Senzel) it is not in any way surprising that HAZMATIPS required" - suggested for inclusion in the packaging test report that the packaging is weight different from that of the board used is "more fragile than plastic at -18°C" (what suitable provided no inner packaging used 1. What is the intent of "Variation en machi ate packagings, 2" in 49 CFR 178.601(g)(2)? kind of plastic?) appears also to run is, the V-marked packaging is supposed to counter to this underlying philosophy. That type]". In the second letter, in response to This variation was agreed to by the UN "each run of corrugated board may provide concerns expressed by the writer that, since to permit, without a full requalification of inner packagings different from those design test, the conditional substitution be authorized for any inner packaging - with no "strings" attached. different [cobb test] results" a certification of discussions that took place at the UN It is entirely possible that my recollection requested by customers that all board pro- tested in the original design tests. This is duced can "pass" the Cobb test should be to be accomplished by drop testing a Committee so many years ago is flawed. edges that no such "blanket statement" is viewed as "unacceptable", DOT acknowl- a greater total combined package weight decidedly most fragile inner packaging at direct knowledge) that the view stated by Nevertheless, I have some concer (but no required by the HMR. Curiously (and than would be authorized for actual ship- other national "competent authorities" when DOT in this letter would not be shared by go on to state that it is nevertheless a almost humorously), however, DOT fails to ment by the markings. The theory was inner packagings in a combined heavier that by using a combination of fragile interpreting the corresponding provisions in requirement (blanket statement to cus- the UN Recommendations, ICAO Technical board used in the manufacture of UN certi- tomers or not) of the HMR that all fibre- unit in a successful drop test, it would be Instructions, ADR. etc. And even if simply testing, for the modified combination safe, without repeating complete design based on the need to ensure a very high level fied 4G outer packagings be capable of "passing" that test! packaging to be used with any suitably of performance with V-marked package in in terms of fibreboard properties means at So, it may be concluded that "identical" protected inner packagings. actual transport - as opposed to strictly sat- isfying the minimum requirements of the encourage the design qualification testing of HMR - I would personally be reluctant to least the same basis weight and capable of 2. Can DOT authorize the use of level in the Cobb test. But it means even meeting the same minimum performance "non-glass" inner packaging a V-marked package with any inner packag- by using in the Variation 2 ing other than one of glass. And fragile glass more, and it is important to take all relevant drop test, an inner packaging (whatever that may be) at that! factors into account in assessing whether that might not be "as fragile as is "virtually identical" to that used in the fiberboard used in production packagings fragile can be» and then quali- Fiberboard Packaging Properties, packagings subjected to the design qualifi- tying its "lesser fragility"? Design Qualification Testing cation tests. In this regard, DOT has previ- ously stated in various interpretations that concept is clear based on one of its "clar- That DOT appears to have adopted this Reference $§ 178.601 and 178.516, found on page 53 of this issue. fibreboards must have the same burst to be "virtually identical" to one another ification letters. But the author points out Letters dated August 2, 2002 to that some doubt may exist about this Mr. Tony Senzel of Corrugated strength, edge crush resistance, water absorption rate, board weights, manner of approach in view of the history of this construction, flute and caliper. Moreover, exception and consequently its potential Supplies Corporation and to DOT has always prefaced such listings of unacceptability by other competent Mir. Richard M. Thomas of properties by the words "such as" - imply- authorities. There might be a question Smurfit-Stone Container Corporation. whether DOT has exceeded the authority ing that other characteristics may be rele- vant to the determination of what is "virtu- agreed upon by the international commu- nection with UN "4G" fibreboard combina- An issue that frequently arises in con- ally identical" (but, unfortunately, never nity. The author believes that any person explicitly stating what these additional very cautiously. [Editor's NOTE: Fragile is using such an approach should do so tion packagings, is what degree of variation ated before the fibreboard is viewed as a in the properties of fibreboard can be toler- characteristics might be!). # may feel that it has more precisely limited not a defined term in the UN and DOT "different" material from that used in pack- what is being authorized.] manh Intornalinnal inc. • 877-429-7447 • Reproduction Prohibited Seriestes/Octrier 2042#

Page 7Apr-22-03 10:16 packg Res 6104369422 P.04 US DOT Interpretations § 178.516 August 2, 2002 I hope this answers your inquiry. aging qualifies under $ 178.601 (g) (2) This responds to your January 29, 2002 letter requesting clarification on package Sincerely, packagings as long as no inner pack- for selective testing of combination testing under the Hazardous Materials Delmer F. Billings agings more fragile than plastic at -18 Regulations (HMR; 49 CFR Parts 171- Chief, Standards Development oC (000) are used? 180). Specifically, you ask if your box office of Hazardous Materials Standards plant can be required to sign a blanket A3. Such a statement is permissible, but statement guaranteeing that fiberboard not required. Variation 2 allows "pass" the 30-minute Cobb Water used in the outer packaging will always § 178.601 July 11, 2002 inner packagings of any type in an outer packaging without retesting if Absorbency Test. You also ask what must pass the Cobb Test, the "combined" ing clarification of selective testing This is in response to your letter request- tion are met. the specific conditions of the varia- (corrugated fiberboard material) or the Materials Regulations (HMR; 49 CFR Variation 2 under the Hazardous only), and, what results to use, an indi- "base material" (outer liner component I hope this information is helpful. If you Parts 171-180). have further questions, please do not indicated in the ISO International vidual result or average of test results as hesitate to contact this office. Standard 535 provisions? Your customer has asked you to test and inner packagings are plastic bottles con- certity a combination package where the Sincerely, According to your letter, 3rd party taining liquids as a Variation 2 packag- Hattie L. Mitchell and/or self-certified labs are requesting that your box plants sign blanket state- ing. Your customer has interpreted Chief, Regulatory Review and Reinvention is used in their outer packaging always ments guaranteeing the fiberboard that an example of a "fragile inner packag- § 178.601 (g) (2)(i to mean that glass is Office of Hazardous Materials Standards ing." believe that this type of practice is unac- "pass" the 30-minute Cobb Test. You § 178.602 July 17, 2002 ceptable since each run of corrugated Your questions are paraphrased and answered as follows: This responds to your April 25, 2002 let- board may provide different results. The ter requesting we consider alternative HMR do not require blanket statements 21. Is it permissible to use plastic inner testing procedures to those under the always pass the Cobb Test. Decisions guaranteeing that the fiberboard will receptacles conditioned to -18°C 49 CFR Parts 171-180). Specifically, you Hazardous Materials Regulations (HMR; regarding such business (0°F) in lieu of glass for the drop should be negotiated between your com- practices test required in § 178.601 (g) (2) (i)? you are recommending for retesting of ask that we consider two options that pany and your customers. A1. The answer is yes. Drop testing of previously certified UN hazardous mate- inner packagings intended to con- combination packagings with plastic rial packages. You state that these rec- In your package testing scenario, the ommended testing procedures will help Cobb Test is conducted on the "com- when the temperature of the test tain liquids must be carried out the environment and reduce waste and bined" (corrugated fiberboard material) costs involved with UN hazardous mate- and it fails to pass the Cobb Test. If the sample and its contents has been rials testing. You further state that these Cobb Test was then conducted on the reduced to -18°C (0°F) § 178.603 (c). (see only when agreed upon by the custome ecommended options are to be use ponent only) that was actually used in actual "base materials" (outer liner com- and testing laboratory performing the the box and the base material passes, 22. Can we certify our combination test. use. Section 178.516 (b) (1) requires the you ask which set of results should you packagings for Variation 2 using plastic inner packagings? You propose the following options: outer surface of the combined board to required for drop tests be reduced to Option #1 - The quantity of packs be tested, not the "base materials" or outer liner component. ISO International A2. The answer is yes, provided the spe- met. cific conditions of the variation are three (3) packs with multiple drops per- age, therefore, the average test results Standard 535 specifies using the aver- rmed on two (2) packs, and Option : Use only two (2) complete filled pack determine whether the fiberboard passes 23. Assuming we can test to Variation 2, recommend these procedures for: (1) for stack, vibration and drop testing. You or fails the Cobb Test. should a statement be included in the certification report that the pack- retest only when no substantial change in supplier or material has been made September/October 2002 Copyright 2002 Packaging Research Intemational, Inc. • 877-429-7447 • Reproduction Prohibited MAZHAT Pachaper & Stiper 53#

Page 8Apr-22-03 10:17 packg Res 6104369422 P.05 Questions « Answers I thereby allowing difterent, less under actual transport, etc.) - fragile inner packagings of lesser NO&A filled weight to be substituted for design qualification tests. the inner packaging(s) used in the MAT Having said this, however, there are still a number of conditions use of V-marked packagings that and limitations that apply to the By Andy Altemos, Technical Advisor must be borne in mind when pack- O: Could you clarify what require- ments must be met relative on the "Selective testing of combina- in § 178.601 (g) (2) as "Variation 2" ing inner packagings in V-marked packages in order to ensure the for hazardous materials? My to using V-marked packagings tion packagings". Packagings con- the regulations. As with any UN package is used in compliance with understanding is that the per- forming to this selective testing formance capabilities of this variation" are frequently referred ed packaging, it is imperative to Specification, performance-orient- tunity to package a wide range product may present the oppor- to as because §§ 178.503(a) (2) "V-marked" packagings and or limitations arising from the adhere to any relevant conditions of hazardous materials by the ings conforming to the variation to be 178.601 (g) (2) (vii) require packag- configured for testing. These are manner in which the package was overestimated how these pack- various modes. Have shipper's the applicable UN packaging code marked with the letter "V" following certification for the packaging, as identified in the test report or precautions must I take with agings can be used, and what (for example, "4GV" or "LAZV" for them? Can they be reused? conforming combination packagings sure" instructions (required under and/or the manufacturer's "clo- with a fiberboard box or removable A: Certainly, the "V-marked" packag- respectively). head steel drum outer packaging, § 178.2(c) of the HMR to be pro- vided by the manufacturer to each ing is a packaging designed and transferred). In addition, in the person to whom the packaging is compliance with the packaging intended to be used to achieve As stated in the introductory sen- requirements for many different underiying purpose of the varia- tence to § 178.601(g) (2), the applicable conditions and limita- case of V-marked packagings, any packagings and under a wide materials in a variety of inner tion is to allow articles or inner array of circumstances. At the assembled as a combination pack- packagings of any type to be Tachnical Actviser to ¡ Andy Altemos is:" same time, it is my experience that "overestimation" of the ability of in many cases there has been an aging and transported without HAZMAT Packager & figuration of inner packaging and need for testing that specific con- Snipper, and is a partner in the firm, HMT S such packagings to be used in a packaging components). This outer packaging (including related Associates, L.C.C, compliant manner owing to a mis- and limitations that attach to the understanding of the conditions allows a variety of inner packag- . Alexandria, VA. Mr. ings that have not been tested in Attemos was formerty Secretarial to the use of such packagings. "design type" to be assembled and the outer packaging as a defined International Civil Aviation Organization's assignment he was international Standards (CAO) Dangerous Goods Pandl, Prior to that While this discussion of "V-marked" offered for transport in compliance packagings will focus on the applica- safety in the transport of these with the regulations. To ensure Coordinator in the U.S. DOT Research & : ble requirements in the DOT Special Programs Administration, in which Hazardous Materials Regulations ("HMR"), readers are advised that nation packagings, the underlying untested configurations of combi- expert capacity he represented the United in the UN Model Regulation and in essentially the same provisions exist aging is to perform the design philosophy of the V-marked pack- States at the meetings of the United Nations (UN) Committee of Experts on the Transport that standard - for example, the international regulations based on with "fragile" inner packaging(s) qualification tests on the package of Dangerous Goods and its subsidiary bod- ies, the International Maritime Organization's IMDG Code and the ICAO Technical under exceedingly conservative Sub-Committee on the Carriage of Dangerous Instructions (and the associated IATA conditions (e.g., from the Packing Goods and served as the United States' mem- the HMR, the basic requirements for Dangerous Goods Regulations). In Group I drop height, with the inner ber on the ICAO Dangerous Goods Panel. the "V-marked" packaging are found gross mass that will be allowed packagings filled to twice the He may be contacted by telephone at 1 (703) 549-0727, or fax at 1 (703) 549-0728. 12 HAZMAT Paskaper 8 Shier Copyright 2002 Packaging Research International, Inc. • 877-429-7447 • Reproduction Prohibited March/April 2042#

Page 9Apr-22-03 10:18 packg Res 6104369422 P.06 * Questions & Answers • tions imposed by § 178.601 (g) (2) must also be satisfied. Some examples of considerations in the use of V-marked packagings aris- itations are outlined below. ing from these conditions and lim- Selective Testing of Combination Packagings. • Variation 2. Section 178.601(g)(2) the use of V-marked packagings is One area commonly overlooked in :; assembled and transported without testing in an outer packaging urider the : Articles or inner packagings of any type, for solids or liquids, maybe thickness of cushioning material the requirement governing the following conditions: between inner packagings and outer packagings (see § 178.601 between inner packagings and *(i) The oüter packaging "must have been successfully tested in accordance regulations require the cushioning (g) (2) (ili) on page 13). Here, the at the Packing Group i drop helght; . with 178.603 with fraölle (e.g. glass) inner packagings containing liqulds than that used in the design quali- material thickness to be not less one half, the gross mass ofinger packagings used for the drop test, ::) the total combined, gross mass of inner packagings may not exceed fication test. So, it is necessary for test report and/or manufacturers the user to consuit the packaging le thickness of sushering materal between inter backaginds and instructions to determine the mini- niner packagings and the outside of the packagingmay.motspe ensure that this minimum thick- mum thickness required, and to a sinale inner nong thickness in the originally tested packaging; Shioning betwee ackaging was used in the original test the thick- always maintained between inner ness of cushioning material is ushioning between Inner packagings máy not be less thạn th thick- packagings and between packagings and the outer packag- inner ng: the original test ne outside of the packaging and the inner pack compared to the hen either fewer or smaller ner packagings are in the design qualification test but a single inner packaging was used offered for transport. In addition, it ing in each V-marked package additio al cushioning mater al must be used to take up, void spaces se nner, packagings used in the drop test), suicient (v) the outer packaging must have successtuly passed the stacking forth n $178.606 of this subpart when empty, i.e; withoat ether inher back- Fast set the V-marked packaging is to be inner packaging, the thickness of used to transport more than one gings Cushioning materials. The total mass of identical packagest the combined m lasstof inner packagings used for the drop te ast be packagings must always be at least cushioning material between inner packagings • CO taba lauds must he completory. that existing between the inner Icient quantity. absörbent materials to absorb the. entire guid Surrou the design qualification test. packaging and outer packaging in the inner packagi the outer padean intended to coman hel The V-marked packaging require-. of few or smaller inner packagings ments specifically address the use As not leakproo or s intended to contain miner Kadi IS not: sittproo - in which case sufficient addition- than used in the tested design type event of lea means of containing anya quid for. bag, or other equaly efficient means of gi must be provider n mee al cushioning material must always be used to take up all void spaces. aining quasa the absorbent matenal (this section must be placed inside the means of containing required in pa The regulations clearly imply that used than were used in the design more inner packagings may be nts; and qualification test (see discussion in ings must bermarked in acco seen tested to Packing Group I Partormance for combination roance 78.603 or his.pa regarding § 178.601 (g) (2) (ili) and above thickness between inner packag- required cushioning The marked aximum gross mass, may not exceed the ing was used in the design qualifi- ings when only one inner packag- gings of the tested combination packaging An additio (the outer packaging plus one half the mass, of the tilled ble requirements are met. cation tests) - provided the applica- y$178.603(a)(2) of this part must include the letter? inemarking March/April 2002 Copyright 2002 Packaging Research International, Inc. • 877-429-7447 • Reproduction Prohibited HAZMAN Packager & Stiper 13#

Page 10Apr-22-03 10:21 packg Res 6104369422 P.O7 Questions & Answers inner packagings than were used in But what about using fewer langer ple, inner packaging and net pack- the design qualification tests? The age quantity limits, and the capabil- applicable requirements, condi- regulations are silent on this, but a ity of inner packagings containing in the regulations and by the tions and limitations as prescribed DOT interpretation letter written in liquids to withstand the prescribed July 2001 suggests that this is per- pressure differential without leak- take appropriate steps to ensure packaging manufacturer, and to missible provided the weight of the employees utilizing these packag- larger inner packaging(s) does not authorized use. * ings are properly trained in their exceed one-half the aggregate gross in the design qualification tests (as weight of the inner packagings used provided in 5 178.601 (g) (2) (i). is silent on the question of the thick- Unfortunately, the DOT interpretation HAZMAT in such a case. It may be assumed ness of required cushioning material Finally, with regard to reuse of V- material between the larger inner that the thickness of cushioning Packager - Shipper packagings and between the larger inner packaging(s) and the outer specifically prohibited from reuse paper, plastic film or textile being Hazmat Tips that existing between the inner pack- packaging must always be at least by § 173.28 (b) (3) of the HMR agings and between the inner pack- ("liberboard" not being consid- Use of V-marked agings and outer packaging in the poses of ered by DOT as "paper" for pur- design qualification test. However, it this However, for practical reasons the prohibition). Packagings would ensure sufficient protection for may be questioned whether this possibility of reusing fibreboard What is a V-marked packaging? a larger, heavier inner packaging. regulations is highly problematic. packagings in compliance with the This is a special type of UN specifica- When V-marked packagings are bulk packagings in S$ 173.28(a) The reuse requirements for non- to be used to meet packaging require- tion packaging designed and intended used for the transport of liquids, inner packagings must be sur- and (b) would apply. Thus, any a variety of inner packagings under a ments for many different materials in rounded with a sufficient quantity packaging showing evidence of of absorbent material to absorb the reduction in integrity (including for a variety of inner packagings that wide array of circumstances. It allows entire liquid contents of the inner punctures, tears, de-lamination, packagings. This includes when etc., in sides or flaps) may not be have not been tested in the outer "larger" inner packagings are used, reused. Closure of the reused nevertheless to be assembled and packaging as a defined "design type" as discussed above. accordance with the manufactur- packaging would have to be in offered for transport. And, of course, as is the case with tionable whether, for example, er's instructions - and it is ques- packaging, the manner of closing any UN Specification combination Which previous means of closure retaping or resealing flaps from Where do 1 find the requirements for V-marked packaging? the packaging must conform to the manufacturer's closure instructions had been removed for even not See § 178.601 (g)(2) in the DOT - for example, in the case of a fibre- removed) would comply with the Hazmat regulations, noted as board box combination packaging, closure method specified by the "Variation 2"(see page 13). box flaps must be closed and the manufacturer for a "new" packag- box sealed with the same type of ing of the same design type. special markings and where do I find Do V-marked packagings require fied by the packaging manufactur- tape or method of closure as speci- So, while the V-marked packaging these rules for how to mark them? er. Moreover, the gross weight of a is an extremely valuable tool to filled packaging may never exceed ensure compliance in the packag- (2) (vii) of the DOT regulations. See §§ 178.503(a)(2) and 178.601 (g) the gross mass indicated in the UN materials in many different inner ing of a wide variety hazardous applied to the package. packaging certification markings conditions and limitations associ- packagings, there nevertheless are Go to Andy Altemos presentation in If the V-marked package is to be ings that must be observed ated with the use of these packag you clarify what requirements must be HAZMAT Q&A, page 12, titled, "Could requirements for air transport must transported by air, all the general ings in their transport operations Readers employing these packag- ings for hazardous materials?" for an in met relative to using V-marked packag- be satisfied - including, for exam- 14 HAZMAT Packager & Shines ale encouraged to review the depth look at V-marked packaging. Copyright 2002 Packaging Research International, Inc. • 877-429-7447 • Reproduction Prohibited Warch/April 2002#

Page 11Letter To: Mr.- John 7/1/0z Ruther ford 02-0124 Corbin, Gigi (DHM12) Sent: From: Burger, Donald To: Wednesday, November 13, 2002 10:45 AM Subject: Cc: Mazzullo, Ed; Wybenga, Frits; Hochman, Charles; Mitchell, Hattie Corbin, Gigi (DHM12) RE: Interpretation relative to the V marked package The as we discussed the only issue with the letter that I see is that we failed to mention that "the plastic inner packages vith that section, the person or laboratory performing the test would already know that the inners need to be "fragile" an eed to be 'fragile' in accordance with 178.601(g)(2)." But with that said, if the package were to be certified in accordanc the need to restate that requirement is redundant. If using the "most fragile" inner package was the intent of the variation, it is not conveyed by the way the variation is written, it only requires the inner package to be "fragile" not the "most fragile". Additionally, it is impossible to make a blanket statement about the fragility of one material in comparison to another. We design of the package. Thus we rely on the vague term fragile to define when this variation can be used. Fragile is can not say that glass is always more fragile that plastic or vice versa; it is all related to the type of glass or plastic and the defined as likely to break if not protected. in each of the other variations bit absent from variation 2. We can only infer that an equivalent level of safety is maintained Finally, the intro to 178.601(g)(2) makes no mention of maintaining an equivalent level of safety; it is specifically addressed through the testing of the "fragile" packages and replacing them with other inner packages. Don B From: -Original Message. Sent: To: Wednesday, November 13, 2002 10:28 AM Corbin, Gigi (DHM12) Subject: Burger, Donald FW: Interpretation relative to the V marked package Would you care to comment on Frits' e-mail. The UN Recommendations do not refer to the "most fragile" and they do not have the statement about an "equivalent level of packaging." Gigi Thanks. From: -- Original Message.... Sent: Mitchell, Hattie To: Corbin, Gigi (DHM12) Wednesday, October 30, 2002 9:21 AM Subject: FW: Interpretation relative to the V marked package Please resolve. Thanks. From: -Original Message--- Sent: Wybenga, Frits To: Mazzullo, Ed; Mitchell, Hattie Wednesday, October 30, 2002 8:28 AM Subject: Cc: Burger, Donald; Hochman, Charles; Richard, Bob; Pfund, Duane Interpretation relative to the V marked package Ed, Hattie - there is an interpretation to the V marked packaging requirement that was written up in the latest Hazmat of sing with the way other competent authorities would view the question. packager and shipper. I tend to agree with Andy's evaluation that we missed the mark on this and are somewhat out 1#

Page 12The intent of the V marked packaging requirements was to take the most fragile inner packaging one could imagine and put it in the package and subject it to testing more severe than normally required. The thought was by qualifying the package with the most fragile inners anticipated the package it would then be suitable for all inner packagings. This thought is lost in the interpretation provided on 1786.601, July 11, 2002. We allow a plastic package but fail to mention that the tested inner must be fragile - the response does not cover the fragility of the plastic inner relative to maintained - we don't mention this either. I haven't read the requirement on manufacturers having to report shortages other inners that may be used. The intro to all the variations emphasizes that an equivalent level of safety must be to package fillers recently but would it be unreasonable to put some notation in there what the limitations on the use of the V marked packaging are? Please take another look at this interp - thanks. Deputy Associate Administrator for Hazardous Materials Safety Frits Wybenga Research and Special Programs Administration U.S. Department of Transportation 400 7th Street, S.W., Room 8321 Washington, D.C. 20590-0001 Tel.: (202) 366-0656 E-mail: frits.wybenga@rspa.dot.gov Fax: (202) 366-5713 Website: http://hazmat.dot.gov/ 2#

Page 13TSA Indianapolis 3173906921 03/17103 03: 33P P.001 Indianapolis Field Office Office of Security and Investigations Indianapolis, Indiana 46241 5420 West Southern Avenue, Suite 203 Federal Aviation Administration Department of Transportation Office: 317-390-6900 Fax: 317-390-6921 FAX Date: 3/17/03 _Time: 1520 Number of pages to follow: Recipient: Hattie mitchell Sender: Reginald McDaniel Agency:RSPA Fax No: Agency: FAA Title: Special Agent Message • Confidentiality Notice The documents accompanying this facsimile transmission may contain confidential information, which is legally facsimile in error, please immediately notify us by telephone lo arrange for return of the original documents to us privileged. The information is intended for the use of the recipient named above. If you have received this and you are hereby notified that any disclosure, copying, distribution, or the taking of any action in reliance on the contents of this facsimile Informalion is strictly prohibited. If you do not receive all pages, please call the above number. (PUBLIC AVAILABILITY TO BE DETERMINED UNDER 5 U.S.C. 552) FOR OFFICAL USE ONLY#

Page 14TSA Indianapolis 3173906921 03/17/03 03:33P P.Ø02 Inland Paperboard and Packngirag, Inc. 8501 Moller Road Indianapolis, Indiana 46268 Phone 317.875.4101 Fax 317.875.4145 July 10,2002 INLAND ^ Temple-Irland Consuary George Cornell Roche Diagnostics 9115 Hague Road Indianapolis, IN 46250 Dear George: Attached is the UN/DOT Cortification for the Variation 2 Plastic Container Large Package shipped by Roche Diagnostics Packing Group I. It should be understood by Roche Diagnostic personnel and by Inland Paperboard and Packaging. Inc. as described in this document. This package has passed the hazardous material performance oriented packaging criteria, personnel that no changes in the packaging, as tusted, can be tolerated, except as permitted by Variation 2. Any modifications of the packaging involving inner containers, outer containers or case scaling method must be re-tested. packaging people. This certificate, or a copy, needs to be present at the packaging and shipping site(s) and should be reviewed with the documents and procedures. You will, most likcly, receive a visit from a Hazardous Materials Enforcement Specialist in the near future to review your inspection. Copies of this cortification have been provided to Inland's Indianapolis, Indiana Box Plant, also a candidate for an • You should remember that a retest of this packaging must be conducted before July 10, 2004 in order for you to maintain compliance. The attached Ten-E report for internal hydrostatic pressure test will expire August 25, 2002. Please contact me with any questions. My teléphone number is 317-875-4130. Sincerely, John At. Pitherford John H. Rutherford Manager, Testing Solutions Group co: G.D. Bowman - Inland Paperboard and Packaging, Inc. Logal Department Ken Benbow - Irland Paperboard and Packaging, Inc., Indianapolis Box Plant Joe Chaille' - Inland Paperboard and Packaging, Inc., Indianapolis Box Plant#

Page 15TSA Indianapolis 3173905921 03/17/03 03: 33P P.003 : • UNITED NATIONS PERFORMANCE TEST RESULTS FOR CODE 4G CONTAINERS • LARGE PACKAGE FOR VARIATION 2 FOR Roche Diagnostics 9115 Hague Road • Indianapolis, IN 46250 Atta.: George Cornell 7/10/02 PA#14602#

Page 16TSA Indianapolis 3173906921 03/17/03 Ø3:33P P.004 Island Paperboard and Packaging, Inc. Indinnapolis, Indiana 46268 8.501 Muller Road Phone. 317.875.4101 Fax 317.875.4145 REPORT NO.: PA# 14602 Current Date: 7/10/02 Page 1 of 6 Largo Package Ior Variation 2- Packing GO#Pople-Jiand Comany INLAND The package described herein was rested for Roche Diagnostics and found to conform to all of the applicable requirements for packagings in Chapter 9 of the United Nations (Orange Book) and UN/DOT Code of Federal Regulations (CFR) Title 49 Part 107 Recommendations on the Transport of Dangerous Goods, ST/SG/AC.10/1/Rev. 9 through 180. This package is certified for rail and truck transport by this ropor. This package has been certified for air transport by testing conducted by Ten-E Packaging (See attachca report). 'The attached Ten-E report will axpire August 25, 2002. A summary of the test results is as follows: TEST INTENSITY Drop Test RESULTS 72 in. Stacking Test Passed 699Ib.. 317.7 kg Vibration Test Passed 60 min. @, 4.3 Hz Passed All test materials were conditioned in accordance with Section 178.602 (d) (1) unless othorwise noted in the Test Procures and Report Form. This sample passed the drop, stacking, vibration, and Cobb size tests, and the packaging design type is considered to meet the performance requirements. The packaging qualifies under Section 178.601(g)(2) for selcctive testing of combination packagings as long as no inner packaging more fragile than plastic at 0°F is used. On the basis of these /USA/Roche Diagnostics, Indianapolis, IN **Last two (2) digits of ycar of manufacture Date:7-10-02 Jobs At. Kitherford Testing Official Company Name: Inland Papcrboard and Packaging, loc. Address: 8501 Molter Road Indianapolis, IN 46268#

Page 17TSA Indianapolis 3173906921 03/17/03 03: 33P P.Ø05 8501 Moller Road Inland Paperbnard and Packagine, Inc. ! Indianapolis, Indisns 46268 Phone 317.875.4101 Fax 317.875.4145 REPORT NO.: PA# 14602 Current Date: 7/10/02 Page 2 of 6 INLAND 1 Temple-Trland Compary TEST SAMPLE DESCRIPTION Closure Description: 28 num thread, 28/400 finish, 250 ml Natural octagonal cap, made by Heinz, Roche Part No. 0509109. Material: Polypropylenc, Pigment Natural. Liner: N/A • Closure Torque: Snug by hand. Bottle Description: 28/400 Buttress, 2 liter bottle with integral handle made by Owens- Brockway. Method of manufacture extrusion blow molding. Part No. 189907400 Minimum wall thickness is.020 inchcs. Matcrial: Natural High Density Polyethylenc Rated Capacity: 2 Liters Maximum fill capacity 2249mL (98% = 2204 mL) Tare Weight: 170 grams with cap Product Specific Gravity: <1.2 Dimensions: O.D. Height: 240 mm O.D. Length: 147 mm O.D. Width: 80 mm Inner Packaging: One plastic bag 23 inches x 18 inches x 34 inches LIDPE, Clear, .002 Mil. Thrce shects of (Universal PIG Absorbonts (grcy in color) made by New Pig Corporation) absorbent material. Two shects placed in the borom of the plastic bag, and inches. one sheet placed on the top of the two small boxes. Sheer size is 19¾ inches by 16 ½ Overpack: Large RSC, 22 inches × 13 ¾ inches × 12 ½ inches, outside dimensions. Manufacturer/Location: Inland Paperboard and Packaging, Inc. Indianapolis, IN Style & Grade: Large RSC, 42-23-35-26-42 C/B Flute (42-X23-L70-M28-42). Average caliper of six sampics for the large RSC = .269 inches. Small RSC, 42-23-35-26-42 C/B Flute (42-X23-L70-M28-42). Average calipat of six samples for the small RSC = 268 inches. Manufacturers Joint: 1 ½ inches, inside glued (Both Large and Small RSC) Closure Method Description: Both top and bottom flaps, 3 inch wide reinforced remoistenable paper tape manufactured by Central Tape Products. (Both Large and Small RSC) R Top Flaps: One strip down the center where the major flaps meet on Small RSO and two strips down center of Large RSC. Bottom Flaps: One strip down the center where the major flaps meet#

Page 18TSA Indianapolis 3173906921 03/17/03 03:33P P.006 8501 Moller Road Inland Paperboard and Packaging, Inc. • lhonc.317.875.4101 F2x 317.875.4145 Indianapolis, Indiana 46268 REPORT NO.: PA# 14602 INLAND Current Date: 7/10/02 A Temple-Inlard Compary Page 5 of 6 XEST PROCEDURES AND RESULTS • DROP TEST Test Conditions: 0° F Container Gross Weight- Tested Weight: 77.6 Ibs., 35.2 kg (Shipping weight will be 38.8 Ibs. (17.6 kg)) Filling Substance: 50:50 Ethylene Glycol/Water plus lead shot Drop Height: 72 inches Drop Height Calculation if Specific Gravity over 1.2 (unless actual product is uscd): Drop Orientations & Results: : CASE DROP ORIENTATION RESULTS COMMENTS 1 Flat on Bottom Passed Flat on Top Passed Flat on Long Side Passed 4 Flat on Short Side Passed 5 Botlom Corner Passed (Use Mig. Joint) Test standard followed was Section 9.7.3 of the United Nations Recommendations on the Transport of Dangerous Goods (Orange Book) and UN/DOT Code of Federal Regulations (CFR) Tille 49 Section 178.603. Passing Criteria: There cannot be any leakage from the inner packagings. The outer packaging should not be damaged to the extent that further transport or safety will be affected.#

Page 19TSA Indianapolis 3173906921 03/17/03 03:33P P.007 Inland 'aperboard and Packaging, Ine. Indianapolis, Indinna 46268 8501 Moller Road Phonc. 317.875.4101 Fax 317.875.4145 : REPORT NO.: PA# 14602 INLAND Current Date: 7/10/02 Page 4 of 6 A Tomple-Toland Company • TEST PROCEDURES AND RESULTS STACK TEST TEST RESULTS: • Test Conditions: Ambient unless otherwise noted Container. Gross Wight - Tested Weight: 77.6lbs., 35.2 kg (Shipping weight will be 38.8 Ibs. (17.6 kg)) Filling Substance: Empty Boxes Maximum Stack Height: 3 meters Test Duration: 24 hours Calculated Required Test Load: 120 in. per 3 meters ÷ 12 ½ in. per box = 9.6 boxes per 3 meters 9 boxes x 77.61bs. per box =698.4 lbs. Used Emerson 8510 static load for 24 hours. All three boxes put on tester at one time. Load (699 Ibs.) for one box was taken times 3 (2097 Ibs.). Test Load Applied: 699 Ibs., 317.7 kg Tests conducted in accordance with United Nations Reconmendations of the Transport of Dangerous Goods; Chapter 9 Gencral Recommendations on Packaging, Section 9.7.6 and UN/DOT Code of Federal Regulations (CFR) Title 49 Section 178.606. Acceptance Criteria: Test samples should not show any signs of deterioration, which would lead to package instability while stacked..#

Page 20TSA Indianapolis 31739Ø6921 03/17/03 03: 33P P.008 ! .." 8S01 Moller Road Inland Paperboard and Packaging, Inc. Indianapolis, Indiana 46268 Phone 317.875.4101 fizx 317.875.4145 REPORT NO.: PA# 14602 INLAND Current Date: 7/10/02 Page 5 of 6 A Semple-Inland Company TEST PROCEDURES AND RESULTS VIBRATION TEST Test Conditions: Ambient unless otharwise noted Container Gross Weight - Tested Weight: 77.6 Jbs., 35.2 kg (Shipping weight will be 38.8 Ibs. (17.6 kg) Filling Substance: 50:50 Ethylene Glycol/Water plus lead shot. Package Orientation: Top-to-bottom Vibration Frequency: 4.3 Hz @.95 G's input energy Test Duration: 60 Minutes Lcak Test Results: Pass X Fail Test standard followed was Scction 178.608 of the UN/DOT Code of Fedaral Regulations (CFR) Title 49. Currently only the United States requires the vibration 1est. assing Criteria: Following the one bour vibration each container is placed on its sid or one hour and if no evidence of Icakage occurs the package is considered to hav passed.#

Page 21TSA Indianapolis 3173906921 03/17/03 Ø3:33P P.Ø0S Inland Paperbosrd and Packaging, Inc. 4501 Moller Road Markering/Technical Center Indianapolis, Indiana 46268 • Phone 317.875.1101 Fax 317.875.4145 REPORT NO.: PA# 14602 INLAND Current Date: 7/10/02 Page 6 of 6 A Temple-Inlund Company TEST PROCEDURES AND RESULTS COBB TEST Test Conditions: 73° F, 50 % RH. • Test Length: 30 minutes per sample Test Equipment: Gurley Cobb Water Absorption Apparatus Sample Size: 5 ¼ x 5 ¼ inch, container ouícr surface : COBB TEST ABSORPTION RESULTS Average (5 samples) 129 (g/m') Passed I.S.O. International Standards 535-1976 (E) Test standard followed was Section 9.6.11.1 of the United Nations Recommendations on • the Transport of Dangcrous Goods (Orange Book) and UN/DOT Code of Federal Regulations (CFR) Title 49 Section 178.516. Passing Criteria: There cannot be an incicase in mass averaging greater than 155 g/m° of water absorbed over a 30 minute period.#

Page 22: Mr. John Rutherford Manager, Testing Solutions Lab Reference No.: 02-0124 Inland Paperboard and Packaging. Inc. 8501 Moller Road Indianapolis, IN 46268 Dear Mr. Rutherford: This letter replaces our letter dated July 11, 2002 which responded to your request for clarification of selective testing Variation 2 under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Our response to "Q1" is revised for clarity. You stated that your customer has asked you to test and certify a combination package where the inner packagings are plastic bottles containing liquids as a Variation 2 packaging. Your customer has interpreted § 178.601(g)(2)(i) to mean that glass is an example of a "fragile inner packaging." Your questions are paraphrased and answered as follows: Q1. Is it permissible to use plastic inner receptacles conditioned to -18 °C (0 °F) in lieu of glass for the drop test required in § 178.601(g)(2)(i)? A1. The answer is yes, provided the inner receptacles are made of "fragile" plastic material. Drop testing of combination packagings with plastic inner packagings intended to contain liquids must be carried out when the temperature of the test sample and its contents has been reduced to - 18 °C (0 °F) (see § 178.603(c)). Plastic packagings manufactured from plastics normally used for hazardous materials, i.e. high density polyethylene, may not be considered as fragile packagings. Q2. Can we certify our combination packagings for Variation 2 using plastic inner packagings? A2. The answer is yes, provided the specific conditions of the variation are met, including the use of a plastic inner packaging that is considered to be "fragile." Reggie Me Dandar FAA 317-390-6914#

Page 23Q3. Assuming we can test to Variation 2, should a statement be included in the certification report that the packaging qualifies under § 178.601(g)(2) for selective testing of combination packagings as long as no inner packagings more fragile than plastic at -18 °C (0 °F) are used? A3. Such a statement is permissible, but not required. Variation 2 allows inner packagings of are met. any type in an outer packaging without retesting if the specific conditions of the variation I hope this information is helpful. If you have further questions, please do not hesitate to contact this office. Sincerely, Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards Corbin:DHM-12:05/31/02 Rewritten:Corbin:DHM-12:11/15/02:cdd Revised:Burger:DHM-20:12/09/02:cdd File: 178.601 SC: Testing#

Page 24CEN TC 261 Date: 2002-07 • EN ISO 16104:2002 CEN TC 261 Secretariat: AFNOR Packaging — Transport packaging for dangerous goods — Test methods (ISO 16104:2002(E)) Verpackung — Verpackungen zur Beförderung gefährlicher Güter — Prüfanforderungen Emballage - Emballage de transport pour marchandises dangereuses — Méthodes d'essai ICS: Descriptors: Document type: European Standard Document subtype: Document language: 1 Document stage: Publicatio J:leng|CENI261|Sc5|Wg16IEN ISO 16104 - 261255|FDIS|RatifiedIEN_ISO_16104_(E).doc STD Version 2.0#

Page 25prEN ISO 16104:2002 (E) Contents Introduction…... 1 Scope 2 Normative references....... ..... Terms and definitions....... .... 4 Test requirements...... .../ 5 Selection and preparation of test packagings...... . 1: .6 Facilities for testing........... ... 11 Test procedures.. 1 Annex A (informative) Light gauge metal packagings... 2 Annex B (informative) Packaging types, codes and references... ... 2i Annex C (normative) Special packagings.. ......... Annex D (informative) Special test requirements... ..... 3l Annex E (normative) Test report and specifications.. ..... 3" Annex F (informative) Selective testing... ... 3! Annex G (normative) Packaging specifications. ... 4° Bibliography.... ..... 51 1#

Page 26Foreword -Packagiument has been prepared by CEN/TC 261, "Packaging" in collaboration with ISO/TC 122 following countries are bound to implement this document: Austria, Belgium, the Czech Republic According to the CEN/CENELEC Internal Regulations, the national standards organizations of the Norway, Portugal, Spain, Sweden, Switzerland and the United Kingdom. Denmark, Finland, France, Germany, Greece, Iceland, Ireland, Italy, Luxembourg, Malta, Netherlands, annexes of the ADR. Therefore in this context the standards listed in the normative references and This European Standard has been submitted for reference into the RID and/or in the technical covering basic requirements of the RID/ADR not addressed within the present standard are normative ADR. only when the standards themselves are referred to in the RID and/or in the technical annexes of the Annexes A, B, D and F are informative. Annexes C, E and G are normative. This standard includes a Bibliography.#

Page 27prEN ISO 16104:2002 (E) Introduction United Nations Recommendations on the Transport of Dangerous Goods [1] and successful passing This Standard was developed to provide requirements and test procedures to meet the multi-modal claimation red ding nice of rese ling or the or pla dang, austing or as. there are agreements and national legislation for the transport of dangerous goods. The international The UN Recommendations are given legal entity by the provisions of a series of international modal agreements include: - The European Agreement Concerning the International Carriage of Dangerous Goods by Road (ADR) (covering most of Europe). [2] most of Europe, parts of North Africa and the Middle East). [3] Regulations concerning the International Carriage of Dangerous Goods by Rail (RID) (covering - The International Maritime Dangerous Goods Code (IMDG Code) (worldwide). [4] - The International Civil Aviation Organization's Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICAO TIs) (worldwide). [5] The application of this Standard will need to take account of the requirements of these international agreements and the relevant national regulations for domestic transport of dangerous goods. variations to tests for light gauge metal packagings and these are included in annex A. Occasionally during adoption as a modal regulation the text has been modified; RID/ADR permit some Agreements are summarized in annex B. The cross references between this Standard, the UN Recommendations and the International It is important to note that there will be certain modal differences from the UN Recommendations and inconsistencies with this Standard, which is regularly updated to the latest version of the UN that the schedule for revision of the Recommendations and modal provisions may lead to temporary Recommendations. It is noted that success in the tests and the allocation of an official UN mark do not on their own instructions published in the various modal regulations. authorize the use of a packaging for any dangerous goods, which are subject to the packing This Standard is based on Revision 12 of the UN Recommendations. 3#

Page 281 Scope standard and intended for use in the transport of dangerous goods. This Standard specifies the design type test requirements for packagings as described in 3.6 of this in the Bibliography. NOTE This Standard should be used in conjunction with one or more of the international regulations set out 2 Normative references publications. These normative references are cited at the appropriate places in the text, and the This European Standard incorporates by dated or undated reference, provisions from other publications are listed hereafter. For dated references, subsequent amendments to or revisions of any revision. For undated references the latest edition of the publication referred to applies including of these publications apply to this European Standard only when incorporated in it by amendment or amendments). (ISO 2206:1987) EN 22206, Packaging — Complete filled transport packages — Identification of parts when testing So rati, Petroleum products - Lubricating groase and petroleum — Determination of cone ISO/IEC 17025, General requirements for the competence of testing and calibration laboratories including Technical Corrigendum 1:1994) EN ISO 2431, Paints and varnishes - Determination of flow time by use of flow caps (ISO 2431:1993, 3 Terms and definitions For the purposes of this European Standard the following terms and definitions apply. 3.1 competent authority in connection with the regulations specified in the Bibliography any national regulatory body or authority designated or otherwise recognized as such for any purpose 3.2 packaging design type nclude various surface treatments together with packagings which differ from the design type only il ackaging of one design, size, material and thickness, manner of construction and packing, but ma their lesser design height liquids and solids (see annex B)#

Page 29prEN ISO 16104:2002 (E) 3.4 capacity brimful (overflow, maximum) capacity to the point of overflowing in its normal position of filling maximum volume of water in litres held by the packaging when filled through the designed filling orifice nominal capacity capacity in litres which, by convention, is used to represent a class of packagings of similar brimful capacities 3.5 packing group the degree or danger pressand articles of most classes of dangerous goods are assigned according to Packing group I Packing group lI Packing group III High danger medium danger low danger or article. The allocation of packing groups to substances and articles may be found in the dangerous goods lis The severity of a packaging test (e.g. the drop height) varies with the packing group of the substance of the UN Recommendations. packaging receptacle and any other components or materials necessary for the receptacle to perform its containment function and are: - designed to contain a net mass not exceeding 400 kg; designed with a capacity not exceeding 450l; — not intended to transport most gases; — not intended to transport most infectious substances; - not intended to transport most radioactive materials; - not Intermediate Bulk Containers as defined in the UN Recommendations 6.5. NOTE 1 Other definitions relevant to this standard may be found in 1.2.1 of the UN Recommendations. regulations. NOTE 2 Annex B contains useful data on packaging types and other identifying codes with references to the NOTE 3 contents. Unless otherwise stated both the 400kg and 450 litre limits apply to all packages irrespective of the "V"-marked packaging (ste anna ging conforming to the appropriate requirements from the UN Recommendations 6.15.1.7 3.8 special packagings collective term for V-marked packaging and salvage packagings (defined in the UN Recommendations 1.2.1)(see annex C) 5#

Page 303.9 single packaging containment function and it includes composite packaging means of packaging that does not require an inner packaging to be capable of performing its 3.10 light gauge metal packaging - (see annex A) NOTE Other definitions that may be relevant to this standard may be found in the UN Recommendations. 4 Test requirements 4.1 General Before the packaging is used for dangerous goods, tests shall be carried out successfully on each shall meet the requirements set out in annex C. Where an inner treatment or coating is applied for safety reasons it shall retain its protective properties even after tests. authority, several tests may be made on one packaging. This may be necessary, for example, with very costly or NOTE Provided the validity of the test results is not affected and with the approval of the competent scarce packagings. This may be accomplished by: a) using one set of packagings for more than one of the tests. For example five tests are required on a drum for liquids, each requiring a set of three packagings, namely first drop, second drop, leakproofness, internal pressure and stack. Subjecting one set to more than one of the five tests is considered equivalent; using one packaging for the tests. For example using one fibreboard box for all five drops is considered equivalent to carrying out 1 drop on each of five boxes. one packaging to more than two tests (including investigatory drops) under method b). Approval should be sought from the competent authority before employing method a) or when subjecting any The use of smaller numbers should be indicated in the test report. This is normally apparent from the serial numbers of the packagings used for the various tests but explanatory text is also desirable.#

Page 31Table 1 — Allocation of test conditions to packaging types Drop test Stacking test (see annex D for variations) Leakproofness Table 1 Contents Inner packaging Temperature Temperature test Packaging type Liquid/ Plastics Other or Other none packagings No. of Ambient | 23°C/ | -18°C packagings No. of Time Ambient | 23°C/ 40° C packagings No. of Time 50 % rh Table footnotes 50%* be (A) (B) (C) (D) (E) (F) (G) (H) (1) (v) (K) (L) (M) (N) (0) packagings * 1. Metal Liquid 3 24 h 3 5m 6 3 24 h Y 6 3 24 h Y 6 3 24 h Y 6 Y 3 24 h Y 3 28 d Y 3 5m Y 3 24 h' y' packagings 8. Composite Liquid 6 Y 24 h' y' 3 5m plastics 9. Composite packagings - Liquid 6 y' Y 3 24 h 3 5 glass, stoneware and porcelain ™#

Page 32Drop test Stacking test (see annex D for variations) | Leakproofness Table 1 Contents Inner packaging Temperature Temperature test Packaging type Liquid/ Plastics Other or No. of Other none packagings Ambient 23°C/ 1-18 °C No. of 50 % rh packagings Time Ambient 40° C No. of d 50% rh packagings Time Table footnotes h be a c d (A) (B) (C) (D) (E) (F) (G) (H) (1) (J) (K) (L) (M) (N) (0) 9a. Composite glass, stoneware packagings - Solid Y 6 3 24 h' and porcelain packagings - 9b. Composite Solid Y 6 3 24 h' y' and porcelain glass, stoneware plywood drums 10. Fibre/ Solid Y 6 3 24 h y' plywood drums 11. Fibre/ Solid Y 6 Y 24 h boxes 12. Plastics Solid 5 y' 3 24 h Y 0 13. Fibreboard boxes Solid Y 5 Y 3 24 h 0 14. Fibreboard boxes Solid Y 5 Y 3 24 h 0 15. Other boxes Solid Y 5 Y 3 24 h Y 0 16. Other boxes Solid Y 5 3 24 h Y | 17. Bags (paper) Solid 3 Y 0 0 18. Bags (other) Solid 3#

Page 33NOTE 1 Annex B Table B.2 shows the relationship between this table and UN packaging codes. NOTE 2Y indicates a requirement " Column (G) and (L): Paper or fibreboard packagings shall be conditioned for at least 24 h in an atmosphere having a controlled temperature and relal 'C conditioning for plastics inner packagings or receptacles takes precedence. The preferred atmosphere is 23 °C ‡ 2 °C and 50 % ‡ 2 % r.h NOTE 1 The two other options are 20 °C + 2 °C and 65% #2% r.h. or 27 °C + 2 °C and 65% ‡ 2 % r.h humidity without significant impairment of test reproducibility. NOTE 2 Average values should fall within these limits. Short term fluctuations and measurement limitations may cause individual measurements to var NOTE 3 Conditioning may be carried out immediately before, or after filling the package with the test contents provided such a procedure would not aff • Column (H): 1) The following plastics packagings shall undergo the cold drop test: — -plastics drums and jerricans; - -plastics boxes other than expanded polystyrene boxes; - -composite packagings (plastics materials); — -combination packagings with plastics inner packagings other than plastics bags intended to contain solids or articles; 2) The temperature shall be -18 °C or lower as measured immediately after the drop test; 3) Test liquids shall be kept in the liquid state by the addition of antifreeze if necessary; NOTE Temperatures outside the range -18° to -22 °C should be pre-arranged and recorded in the test report; "Column (M): The temperature shall be at least 40°C. NOTE Temperatures outside the range 40°C to 44 °C should be pre-arranged and recorded in the test report. •h= hours d = days m = minutes •Column (H): Metal packagings with plastics closures not exceeding 7 cm shall not undergo the drop test at - 18 °C as required for plastics packagings. 'Column (H): Expanded polystyrene boxes, unless inner packagings are of plastics material, shall not undergo a drop test at - 18 °C; the drop shall be a & Column (R): Packagings shall be at least 48 h old. " Contents of inner packagings can be solid or liquid.#

Page 34'Column (J): — Composites with plastics outers shall be tested for 28 days at 40 °C; — Composites with outers other than plastics shall be tested for 24 h at ambient temperature. ' Column (Q): Plastics packagings and Composite packagings (plastics materials) shall be tested for 30 min. Other composites shall be tested for 5 mil * Column (A): Other than boxes. 'Column (G) and (K): where the outer is fibre/fibreboard the drop and stacking test shall be undertaken following conditioning at 23°C + 2°C and 50 % the procedures for boxes see Table 2. ™ Column (A): where a composite packaging (plastics materials) is in the shape of a box only 5 samples are required for the drop test which shall be ca#

Page 35prEN ISO 16104:2002 (E) 4.2 Drop test When tested in accordance with 7.1: a) the packaging shall be leakproof subsequent to any slight discharge from the closure(s) that may be apparent at the moment of impact and, in the case of packaging containing liquids, subsequent to the equalization of internal and external pressures (except for inner packagings of combination packagings when it is not necessary for the pressure to be equalized); b) the packaging shall not exhibit any damage liable to affect safety during transport, for example the package cannot be moved without leaking; c) the packagings that are to be tested for use with goods of Class 1 (explosives) shall be identified as of loose explosive substances or articles from the outer packaging; such in the test report. When tested, they shall not display any rupture that would permit the spillage d) the outer ply of a bag shall not exhibit damage liable to affect safety during transport; e) the outer of a combination packaging shall not exhibit damage liable to affect safety during transport. 4.3 Stacking test When tested in accordance with 7.2 the packaging shall not: a) show any sign of leakage (this includes inner packaging and any inner receptacle); b) show any deterioration which could adversely affect transport safety nor any distortion liable to reduce its strength or reduce stability in stacks of packages. 4.4 Leakproofness test combination packagings) shall be leakproof. When tested in accordance with 7.3, packagings intended to contain liquids (except inner packagings of 4.5 Hydraulic pressure test When tested in accordance with 7.4, packagings intended to contain liquids (except inner packagings of combination packagings) shall not leak. nner packagings of combination packagings containing liquids, which are likely to be shipped by air, sha e capable of withstanding an internal pressure without leakage (see UN Recommendations 4.1.1.4.1. 4.6 Test report All packaging tests performed in conformity with this standard shall be the subject of a test report and will ineude as priating rect peed tet rear, the by the retention or sile real, packagings or by inclusion of sufficient photographs and/or drawings with unique references to enable The test report shall be available to the users of the packaging. packagings should provide information regarding procedures to be followed and a description of the types and The complete test report may not be required by the user. Manufacturers and subsequent distributors of presented for transport are capable of passing the applicable tests). dimensions of closures (included required gaskets and any other components needed to ensure that packages as#

Page 365 Selection and preparation of test packagings 5.1 Selection of packagings columns E, I, N and P of Table 1 and shall be Sufficient packagings per design type shall be selected/submitted for testing in accordance with the test repo with a test reference which shall also be entered on the test record and later used on 22206; b) marked on each face where the packaging is in the shape of a box in accordance with EN c) individually weighed to establish the tare or filled mass; have been supplied full or empty to the test station. Where the masses of individual empty d) NOTE The form of such weighing may be varied to correspond to whether the packagings packagings are recorded, it is necessary to record only a typical filled mass (or vice versa); replaced. e) examined for damage which might invalidate the tests, in which event the packaging shall be NOTE Under some circumstances it may be desirable to have a range of packagings tested in a number of different sizes but of the same construction. In such situations it may not be necessary to carry out testing for competent authority who will advise on options available. Guidelines are set out in annex F every possible permutation. This selective testing procedure is recognized but only after agreement with the 5.2 Information to be provided with packagings 5.2.1 General data set out in annex G and by the following additional information as relevant. Each packaging type shall be accompanied by specification(s) for that design type containing the 5.2.2 Test Contents- Using water and non-dangerous substances of the packing group for which the packaging is to be tested shall be provided, together with data Where the tests are to be carried out using water or other non-dangerous substances a statement required maximum relative density for the tests together with data on, for instance, the internal enabling appropriate selection of inert test contents. For liquids such data will normally include the pressure test required. For solids such data shall include mass, grain size and any other relevant characteristic, for example, bulk density, angle of repose etc., to clearly show equivalence of 5.2.3 Test Contents - Using the dangerous substance shall be defined by their mass and grain size and any other relevant characteristic, for example, included. This data shall be recorded in the test report (see annex E); bulk density, angle of repose etc. to ensure physical characteristics are sufficiently identified and be applicable for other substances having the same or equivalent characteristics VOTE Where tests are carried out using the actual substance to be transported then the test report shoul#

Page 37prEN ISO 16104:2002 (E) 5.2.4 Test Contents- Using Articles appropriate description and drawing(s) of the articles) and or photographs and details of the way in Where the packaging is intended for the transport of an articles), a statement of the packing group, an which dummy articles were filled for the purpose of testing. 5.2.5 Vapour pressure For liquids the vapour pressure of the substance to be carried or the hydraulic pressure to be achieved during the tests. 5.2.6 Special instructions Any special filling or closing instructions including, where relevant, for example the closure torque (EN 26789). 5.3 Selection of contents and filling of packaging prior to testing 5.3.1 General stacking tests to not less than: Single packagings and the inner packagings of combination packagings shall be filled for drop and - 98% of brimful capacity for liquids; - 95% of brimful capacity for solids. transported part full (see 5.3.6). NOTE There are two exceptions, some flexible packagings (see 5.3.5) and some packagings designed to be 5.3.3 or 5.3.4. Otherwise the capacity shall be determined by other suitable means e.g. by calculation. Packagings for liquids, or those capable of containing them, shall have their capacity determined as in 5.3.2 Test Contents Where non-dangerous substances are to be used as test contents they shall be selected to accord with the data referred to in 5.3.5. Water or a water/anti-freeze mixture may be used to represent any liquid. they shall be placed in such a manner that the test results are not affected. Dangerous articles shall be For solids, additives such as bags of lead shot may be used to adjust the mass if required, but if used the articles to be transported. replaced by dummy articles and these shall be of the same size, shape, mass and centre of gravity as The test contents used shall be recorded in the test report. 5.3.3 Rigid packaging to contain liquids 5.3.3.1 Determination of brimful capacity brimful (overflow) capacity is A packaging intended to contain liquids shall be filled to not less than 98% of the brimful capacity. The losures (mass empty (m) in kg) and weighing the packaging full (mass brimful (W) in kg). The determined for example by: weighing the empty packaging including packaging shall be filled with water until the water just overflows and then fitting the closure and any surplus mopped up. No steps shall be taken, e.g. by tilting or tapping the packaging, to enable water to penetrate into a hollow handle or other design feature above the closure. 13#

Page 38• b= W-m d where: b is the brimful capacity in litres Wis the mass in kg, of packaging when brimful with water m is the mass in kg, of the empty packaging d is the density of water (=1) in kg/litre 5.3.3.2 Filling of the packaging When filling test packagings with liquids, at least one packaging shall have its capacity and filling level of brimful capacity. The calculation of required volume of liquids for testing shall be: c= bx98 100 where: C is the required volume of water in litres; b is the brimful capacity in litres 5.3.4 Rigid packaging to contain solids the packaging is capable of containing liquids the capacity shall be determined as in 5.3.3.1 Packaging intended to contain solids shall be filled to not less than 95% of the brimful capacity. Where The calculation of required mass of solids for testing shall be: • M= (bx d)x 95 where: M is the required mass in kg, of solids; b is the brimful capacity either measured or calculated in litres ; d is the bulk density of the test contents in g/cm 3 brimful capacity shall be calculated from its internal height, taking into account any reduction in height Alternatively, for cylindrical packagings the level of fill required to fill the package to at least 95% of its caused by the fitting of the closure. This procedure is not suitable for bags (see 5.3.5 below).#

Page 39prEN ISO 16104:2002 (E) 5.3.5 Flexible packagings to contain solids packaging intends it to be used or, if known, to the capacity which the user intends to employ using either Flexible packagings (bags) shall be filled to the required testing mass at which the designer of the naracteristics; the test contents used shall be recorded in the test report he substance to be transported or solids of similar characteristics in respect of mass, grain size and flow NOTE should therefore specify the quantity by mass and bulk density of that solid substance, as tested, for which the bag Bags do not have a capacity which is measured in the same way as for rigid packagings. The test report may be used. 5.3.6 Packaging designed to be used part full for solids shall be filled as prepared for transport to the capacity the user intends to employ. The filled Packaging designed to be transported with filling test levels less than 98% for liquids or less than 95% volume and mass shall be recorded in the test report. 5.4 Closing packagings The packagings shall be closed as for transport in accordance with any special instructions. 5.4.1 Drums, jerricans, composites and inner packagings Screw type closures shall be tightened to the torque specified by the applicant where appropriate, which shall be recorded in the test report. closure torque following a failure in one test, then all tests shall be completed using that torque setting. Closure torque shall not differ from one test to another in the test report. If it is necessary to revise a luring or after the conditioning period. The closure torque shall be recorded in the test report crew type closures shall be tightened to an appropriate torque before conditioning, or when specifie Figure 1) and observed for leakage for a period of 5 min. Leakage from the closure vent shall be regarded as a failure. 1 • 2 a) Acceptable b) Unacceptable Key 1 Liquid level 2 Closure Figure 1 - Packagings fitted with vented closure, laid on their side 15#

Page 405.4.2 Bags The packagings shall be closed as they would be for transport. same equipment and the same filling time should be used whenever practicable. To ensure that the test packagings are closed in a manner representative of production packagings, the 5.4.3 Other packaging Packaging for solids shall be filled as in 5.3.4 and closed in accordance with any special instructions including any fitments, cushioning etc. defined in accordance with the specifications (see annex G) The closure elements used to secure the packagings (e.g closure tape, where applicable), shall be 5.4.4 Removable head drums and jerricans Removable head drums and jerricans for liquids shall not be tested for 24 h after being filled and closed to allow for gasket relaxation. 6 Facilities for testing 6.1 General Requirements Tests shall be carried out at a testing facility capable of meeting the operational provisions of ISO/IEC 17025. NOTE 1 external approval may be obtained from either a national accreditation body or from the competent authority. This does not imply a requirement for third party certification or accreditation but if appropriate such NOTE 2 the UN Recommendations. Testing staff should have a knowledge of the principles of the dangerous goods regulations as set out in 6.2 Accuracy of measurement equipment testing, as specified in 6.3, unless otherwise approved by the competent authority. The measuring The accuracy of measuring equipment shall be more precise than the accuracy of the measurements in equipment shall be calibrated in accordance with the relevant provisions of ISO/IEC 17025. 6.3 Accuracy of measurements in testing Measurement equipment shall be selected such that individual measurement results including errors in reading and calibration shall not exceed the following tolerances: Mass in kilograms (kg): *2% Pressure in kilopascals (kPa): * 3% Distance/ length in millimetres (mm): * 2% Temperature in degrees Celsius (°C): *1 °C Humidity in percentage (%): Tolerances are as specified in the agreed test methods Time in minutes (min): * 3% Torque in newton metres (Nm): ‡ 3 Nm or 10% whichever is the greater NOTE when measuring masses or dimensions of empty packagings. For some measurements the tolerances may be lower in order to have meaningful measurements, e.g. Where only maximum or minimum values are specified in the text, tolerances are one-sided, e.g. in 7.3.3 the test pressure may exceed 30 kPa for packing group I but shall not be less. 6.4 Climatic conditions There shall be adequate climatic facilities to meet the requirements in Table 1.#

Page 41prEN ISO 16104:2002 (E) 6.5 Impact surfaces for drop tests enough to be non-deformable under test conditions and sufficiently large to ensure that the test package The drop test area impact surface shall be horizontal and flat, massive enough to be immovable and rigid falls entirely upon the surface. 7 Test procedures 7.1 Drop test 7.1.1 Conditioning Where climatic conditions are critical to the performance of the materials or to the application of the 1 other circumstances, the tests shall be carried out in atmospheric conditions which approximate t ackage, the tests shall be carried out in conditions identical to those used for conditioning (see Table 1) those used for conditioning. The elapsed time between the removal of the packaging from conditioning and its submission to the test shall be kept as short as possible and in any event not more than 5 min. 7.1.2 Drop heights 7.1.2.1 For solids and liquids For solids and liquids, if the test is performed with the solid or liquid to be carried or with another substance essentially having the same characteristics, the drop height shall be that specified below: Packing group I 1,8 m 1,2 m Packing group I| Packing group III 0,8 m 7.1.2.2 For liquids if the test is performed with water 7.1.2.2.1 Relative density not exceeding 1,2 For liquids if the test is performed with water and where the substances to be transported have a relative density not exceeding 1,2, the drop height shall be that specified below: NOTE The term water includes water/antifreeze mixtures for testing at -18°C 1,8 m Packing group I Packing group I! 1,2 m Packing group Ill 0,8 m 7.1.2.2.2 Where the substances to be transported have a relative density exceeding 1,2, the drop height shall be Relative density exceeding 1,2 decimal. The drop height shall be: calculated on the basis of the relative density (d) of the substance to be carried, rounded up to the first Packing group II dx1,0 m Packing group I!! d× 0,67 m 7.1.2.3 Corrections to the drop height for packagings with the density of solids There shall be no correction of drop height with density of solids. 7.1.2.4 Where the inner packagings contain liquid substances of various densities the drop test shall be based Corrections to the drop height for packagings with various densities on the most severe packing group (of the liquid substances to be transported) and the average density. relative density of the contents of that inner packaging and aggregating the results and 7.1.2.2.2 shall be The average density shall be calculated by multiplying the fill volume of each inner packaging by the applied. NOTE subjected to different drop tests set out in annex A. Light gauge metal packaging referred to in European road and international railway regulations may be 17#

Page 42Packaging No. of test Table 2 - Drop orientation Aluminium drums Steel drums samples Drop orientation Explanatory notes The first drop First drop (using three packagings): Non-removable head drums strike the targ Steel jerricans ncluding light gauge meta Aluminium jerricans the second and three for the packaging shall strike the target diagonally on the chime or, if the Open head drums strike the target on the b on a circumferential seam or an edge adja drop) packaging has no chime, on a circumferential seam or an edge. junction of the top and side seams is withir or junction of top and side seams, such tha Second drop (using the other three packagings): the packaging shall pattern. strike the target on the weakest part The second drop orientation is selected tak not tested by the first drop, for of the package type. information drops, (see 7.1.4) and/or any p example a closure or, for some longitudinal seam of the drum body cylindrical drums, the welded Plywood boxes one for each Five Second drop: flat on the top First drop: flat on the bottom 1. The third and fourth drops are conducter Fireboard bo ood boxes drop) Third drop: flat on the long side most likely to cause failure of either the bo› Fourth drop: flat on the short side may be necessary to conduct an investigat Steel or aluminium boxes Plastics boxes Fifth drop: on a corner other packagings. A failure following an inv are in the shape of a box Composite packagings which packaging has been dropped. This is indic EN 22206. seam Bags: single-ply with a side Three (three First drop: flat on a wide face Following each drop the contents of the ba drops per bag) Third drop: on an end or the bage seam, or multiply Bags: single-ply without a side Three (two drops per bag) Second drop: on an end of the bag First drop: flat on a wide face Following each drop the contents of the ba#

Page 43EN ISO 16104:2002 (E) 7.1.3 Test method distance between the lowest point on the package at the time of release and the nearest point on the impact The test package shall be lifted and held in the predetermined orientation at the drop height as defined by the surface. For other than flat drops the centre of gravity shall be vertically over the centre of impact. Prior to carrying out the test ensure that the drop area is clean and dry. Release the test package from its predetermined orientation. 7.1.4 Information drops drops may be performed. Where such investigation drops are undertaken they may be with packagings already Drop orientations for individual packaging types are set out in Table 2. To assess the weakest point, information used in earlier tests. Each packaging shall strike the target in an orientation designed to investigate the weakest part. The orientations to be taken into account vary with designs. The exact orientation chosen should take into account the following impacts: a) directly onto a closure; b) onto a chime such that the crush pattern passes through the closure, closure flange or junction of the top and side seams; c) flat onto the body; d) onto different corners. NOTE 1 Failure in an information drop does not constitute failure of the design type test. than those used for the first drop. NOTE 2 When packagings are available there is no objection to information drops being carried out on other packagings NOTE 3 be conducted. When packagings under test are of a new or significantly modified design, more than three investigatory drops may NOTE 4 The drop should take place on an area of the packaging not already tested. NOTE 5 Where information drops have been undertaken they may be reported in the test records. 7.1.5 Method of assessment be assessed according to procedures in 7.1.5.1 and combination packagings or packagings containing articles Following each drop there shall be an assessment of the result. Single packagings containing liquids or solids shall shall be assessed according to 7.1.5.2. 7.1.5.1 Single packagings for liquids or solids recorded in the test report with an indication of the amount and the source of the discharge and whether or not it At the time of impact the packaging shall be observed for discharge. If such a discharge is observed it shall be could lead to further leakage. The packaging shall be visually examined for leakage and rupture. normally by loosening then retightening a closure, or by making a small hole in the body or end of the packaging. Any packaging containing liquids shall have the internal pressure equalized with the atmospheric pressure, Impacted closures or closures suspected of leaking during the drop shall not be disturbed. When there is only one closure and it is suspected of leakage, pressure equalization shall be achieved by making a small hole in the body or end of the packaging. .-#

Page 44EN ISO 16104:2002 (E) in the same orientation for examination of any leakage which may occur (e.g. moved so that it is on a surface such If there is dampness in the dropping area the packaging may be moved carefully to a suitable place and maintained as clean fibreboard where drips will be apparent). Examination shall continue for a period of 5 min to10 min. retained by an inner receptacle (e.g. a plastics bag, even if the closure is no longer siftproof. Where a packaging for solids undergoes a drop test, the packaging shall pass the test if the entire contents are Where a packaging undergoes a drop test at -18 °C, immediately after dropping the first specimen the temperature not need the temperature checked unless the first sample had not achieved at least -18 °C. of the package and/or its contents shall be checked and recorded in the test report. Subsequent packagings shall 7.1.5.2 Combination packagings and packagings containing articles At the time of impact observe the packaging for discharge. NOTE 1 packaging (e.g. a stain). For inner packagings or articles discharge might appear as dampness in the drop test area, or on the outer NOTE 2 For inner packagings or articles containing solids discharge might appear as loose solid in the drop test area or within the outer packaging. The packaging shall be visually examined for leakage and rupture e.g. escape of the inner packagings / articles. if the entire contents are retained by the inner packaging or inner receptacle (e.g. plastics bag) even if the closure Where a packaging containing inner packagings or articles undergoes a drop test, the packaging shall pass the test is no longer sift proof. If there is dampness in the dropping area, the packaging shall be moved carefully to a suitable place for drips will be apparent). Examination shall continue for a period of 5 min to 10 minutes. examinaton or any leakage that may occur (e.g. moved so that it is on a surface such as clean fibreboard where temperature of the package and/or its contents shall be checked and recorded in the test report. Subsequent Where a packaging undergoes a drop test at -18 °C, immediately after dropping the first packaging, the packagings do not need the temperature checked unless the first sample had not achieved at least -18 °C. 7.2 Stacking test 7.2.1 General packagings, calculation ot stacking loads, methods of test etc. are dealt with here; aspects such as conditioning Stacking tests are required for packagings other than bags (e.g. drum/jerrican or box). Aspects such as number of and period of test being dealt with in Table 1. In the following calculations, where the design type has an effective packaging height. interstacking feature an appropriate allowance shall be made. This normally takes the for of a small reduction in 7.2.2 Calculation of the stacking load 7.2.2.1 Solids, articles, or the actual liquids on each packaging shall be calculated as follows: Where the contents are solids, articles, or the actual liquids to be transported the stacking load to be superimposed My = MC(HIh) - 1) where: Is the stacking load in kilograms (kg); (with closure included) (See Note) M Is the mass in kilograms (kg) of the complete, filled and closed packaging as prepared for transport; Is the relevant stack height in millimetres (mm) (minimum 3000 mm); h Is the overall height in millimetres (mm) of packaging to be tested, allowing for any interstacking features (see 7.2.1). NOTE The newton as a unit of force may be used.#

Page 45EN ISO 16104:2002 (E) 7.2.2.2 Water Where water is used as test contents, the stacking load to be superimposed on each packaging shall be calculated from the following: M. = ((HIh) - 1)(C.d.n+m) where: Is the stacking load in kilograms (kg) (see note); H Is the relevant stack height in millimetres (mm) (minimum 3000 mm); h 1, the overal height of the packaging in millinetres (m) allowing for any interstacking features (see C Is the volume of water in litres (l) required to occupy 98% of the brimful capacity or, for combination packagings, 98% of the brimful capacity of one inner packaging (see 5.3.3.1) d' Is the relative density of the substance to be transported; m Is the mass in kilograms (kg) of the empty packaging (including its closures) or, for combination 7.2.1); packagings, the mass of all the components of one package, including empty inner packagings (see Is the one or a number of inner packagings (combination packaging only). NOTE The newton as a unit of force may be used. 7.2.3 Test methods and criteria • 7.2.3.1 General Any one of three methods shall be used by agreement between the test laboratory and client: a) an unguided load on an individual packaging; b) a guided load on packaging(s); c) an unguided load on three packagings forming one layer, NOTE packaging base shape as the lowest component of the stack. Where a packaging has an interstacking feature the stack loading may be applied using a reproduction of the The method used shall be stated in the test report. 7.2.3.2 Unguided load on an individual packaging 7.2.2) shall be placed centrally on the top for the period of time stated in Table 1 for the particular packaging type. The packaging shall be placed on a firm level surface. The predetermined load (calculated in accordance with The load shall typically be made up of concrete or steel masses. Except where the inter-stacking design is being taken into account, the load shall be applied via a rigid top plate extending beyond the outermost edges of the packagings. The load shall be free to move when and if the packaging collapses. with sufficient slack in the chains not to affect the integrity of the test. Measurements of the deflection and angle of the plate with For safety reasons, however, the load may have restricted movement, e.g. suspended by chains from overhead but a) horizontal are normally made: b) immediately before and after placing the load on the plate c) where appropriate, at intervals throughout the duration of the test; on completion of the test 7.2.3.3 Guided load on packaging(s) A suitable guided load rig shall be used. Such a rig shall take the form of: — a conventional compression testing machine with the facility of maintaining a constant load (as calculated in 7.2.2) for the required period;#

Page 46EN ISO 16104:2002 (E) NOTE Such equipment may have short term fluctuations of ‡ 4% in accordance with EN ISO 12048; - a purpose-made rig, e.g. two frameworks with the upper framework being free to move vertically and with a minimum of friction in relation to the lower framework and to take the appropriate load. For each test the upper framework shall be loaded so that its total mass is that calculated as in 7.2.2. 7.2.3.4 Unguided load on three packagings forming one layer Packagings shall be placed in the same direction on a firm level surface as illustrated in Figure 1. Figure 2 — Plan view of drums stacked as in 7.2.3.4 The spacing between the packagings shall be as close as possible but sufficiently separated to ensure that they cannot come into contact with one another when deformed. plate and suitable masses evenly distributed on it. The load shall have mass of three times that as in 7.2.2 for one A steel plate shall be placed over the packagings, its position shall be carefully checked. The load consists of the packaging (i.e. M1× 3). NOTE Measurements of the deflection and angle of the plate with horizontal are normally made: a) immediately before and after placing the load on the plate; b) where appropriate, at intervals throughout the duration of the test; c) on completion of the test. 7.2.3.5 Methods of assessment: a) There shall be no leakage from the packaging, any inner packaging or any inner receptacle. b) The packaging shall not show any deterioration which could adversely affect transport safety nor any distortion liable to reduce its strength or reduce stability in stacks of packages. (See Notes below)#

Page 47EN ISO 16104:2002 (E) Plastics packagings shall be cooled to ambient temperature before assessment. NOTE 1 °. The 5° criterion has been found to accord with the UN requirements in relation to stack stability Where unguided loads have been used this may be assessed by the angle of the top plate which should not excee same type should be placed centrally on the tested packaging. These two packagings should maintain their position for on OTE 2 Where guided loads have been used, the packagings are removed from the stack rig. Two filled packagings of the 7.3 Leakproofness test 7.3.1 Applicability All packages intended to contain liquids except the inner packagings of combination packagings. 7.3.2 Preparation The method of making pressure connections shall not affect the results of the test e.g. a connection through a closure shall not reinforce that part of the package. There are two methods as follows: a) Drill two holes into the body or head of each packaging. One hole shall be used to connect the packaging to an adequate air supply, the second hole shall be used to connect a pressure gauge reading the test pressure in the packaging; or b) Drill one hole in the body or the closure of each packaging. The gauge shall be connected to the air supply line between the source of the air supply and the packaging and as near as possible to the packaging; the gauge shall only be read under no flow conditions. the appropriate torque. Each packaging shall be closed according to any special instructions. When relevant, closures shall be tightened to Vented closures shall be replaced by similar non-vented closures or the vent shall be sealed. 7.3.3 Test pressure The following minimum test pressures shall be used: 30 kPa Packing group I 20 kPa Packing group II Packing group I!! 20 kPa 7.3.4 Test method Each packaging shall be placed in a tank of water and shall be restrained just below the surface (the method of which shall remain at or slightly above the predetermined level for a period of 5 min. restraint shall not affect the test results). Air shall be applied continuously and gradually up to the required pressure 7.3.5 Method of assessment Each packaging shall be visually monitored throughout the test. No packaging shall leak. NOTE Air bubbles considered to arise from entrained air (e.g. air held initially which do not appear regularly in seams or in the thread of closures) should not be considered as leakage: these include any bubbles produced at intervals exceeding 1 min. If necessary, the test period should be extended to allow entrained air to be expelled. 7.4 Hydraulic pressure test 7.4.1 Applicability All packages intended to contain liquids except the inner packagings of combination packagings. test or stacking test. NOTE 1 The internal pressure test may be carried out on packagings which have successfully undergone the leakproofness NOTE 2 This test method would meet the UN requirements for assessing inner packagings for air transport. 7.4.2 Preparation for the internal pressure test Each packaging shall be prepared as described in 7.3.2 and completely filled with water. NOTE Steps should be taken to ensure that no air remains inside the packagings above the level of the closure by, for example, tilting the packaging when filling. Vented closures shall be replaced by similar non-vented closures or the vent shall be sealed. -#

Page 48EN ISO 16104:2002 (E) 7.4.3 Determination of test pressure The hydraulic gauge pressure shall be applied, determined by one of the following methods: a) not less than the total gauge pressure measured in the packaging (i.e. the vapour pressure of the filling liqui 1.5; this total gauge pressure shall be determined on the basis of a maximum degree of filling in accordance and the partial pressure of the air or other inert gases, minus 100 kPa) at 55 °C, multiplied by a safety factor o with UN Recommendations Part 4.1.1.4 and a filling temperature of 15 °C; b) not less than 1,75 times the vapour pressure at 50 °C of the liquid to be transported, minus 100 kPa but with a minimum test pressure of 100 kPa; c) not less than 1,5 times the vapour pressure at 55 °C of the liquid to be transported, minus 100 kPa but with a minimum test pressure of 100 kPa. For packagings to transport packing group I liquid, the minimum test pressure is 250 kPa (gauge) 7.4.4 Test method The packagings shall be pressurized continuously and gradually up to the required test pressure. NOTE This should be within the time of not less than 2 min and not greater than 15 min. of Table 1. The pressure in the packaging shall remain at or slightly above the predetermined level. The manner in The pressure in the packaging shall be held continuously and evenly for the appropriate period shown in column Q which packagings are supported shall not invalidate the test. 7.4.5 Fillings for plastics drums and jerricans temperature of the water measured. Water at the same temperature shall be used to pressurize the container. If For plastics drums, jerricans and composite packagings (plastics) each packaging shall be filled with water and the the water temperature is outside the limits 12 ‡ 2 °C, a factor shall be applied from Table 3 to adjust the test pressure. Where the water temperature is (12 ‡ 2) °C the pressurization factor is 1.000. number) and the pressurization factor shall be read from the table below: Outside these limits the temperature shall be rounded to the nearest 1 °C (0,5 °C goes up to the next whole Example: For a required test pressure of 250 kPa, tested at a water temperature of 6,1 °C Applied test pressure = 269 kPa = 250 × 1,078 kPa The temperature of the water from one sample and the applied test pressure shall be recorded in the test report for plastics drums, plastics jerricans and composite packagings (plastics)#

Page 49EN ISO 16104:2002 (E) Table 3— Water temperature adjustment factors for plastics packagings Water temperature °C Pressurization factor 2 1,132 3 1,119 4 1,105 5 1,092 6 1,078 1,065 8 1,051 9 1,038 <10 1,025 12+2 1,000 >14 0,976 0,964 16 0,952 0,940 0,928 19 0,917 20 0,906 NOTE For temperatures above 20 °C use a pressurisation factor of 0,906. 7.4.6 Method of assessment Each packaging shall be visually monitored throughout the test. No packaging shall leak. eakage - as a guide 1 drop of water every two minutes VOTE Water drops originating from water held initially in seams in the thread or in gaskets should not be considered a 7.5 Reassessment when failure occurs If failure occurs, the tests on the packagings submitted shall be ended unless one of the reassessment procedures set out below is used: a) The tests shall be repeated at a lower level of intensity. For example, if two packagings pass and one fails, the hydraulic pressure test at 200 kPa, a fourth packaging shall be tested at 150 kPa and the design type shall be regarded as passing at the latter level; b) Where only one packaging fails on one test, that test shall be repeated on twice the normal number of identical packagings for that test. If they all pass, the design type shall be regarded as meeting the test requirements; The use of this procedure can be illustrated by the following example: Where one of the three test packagings fails the drop test in the second orientation, but all the other test pressure and stacking), then six packagings shall be tested in the second orientation. packagings have passed the drop test in the first orientation and the other tests (namely leakproofness, internal 7.6 Recording of reassessment Where a reassessment procedure is used, this shall be fully recorded in the test report. --#

Page 50EN ISO 16104:2002 (E) 7.7 Equivalent testing The test methods described in this standard shall be considered to be the reference test methods. NOTE Alternative methods may be used to demonstrate compliance with relevant regulations provided that: - their equivalency to the reference test method can be demonstrated - their use is recorded in the test report prior approval is obtained from the competent authority •#

Page 51EN ISO 16104:2002 (E) Annex A (informative) Light gauge metal packagings A.1 European considerations The European Agreement Concerning the International Carriage of Dangerous Goods by Road (ADR) and the Drop heights for light gauge metal packagings for use under RIDIADR shall be as follows: a) if the relative density of the substances to be carried does not exceed 1,2, the drop height should not be less than that specified below: Packing group lI Packing group I!! 0,6 m 0,4 m • b) if the substances to be carried have a relative density exceeding 1,2, the drop height should be calculated on the basis of the relative density (d) of the substance to be carried, rounded up to the first decimal place. The drop height should not be less than that specified below: Packing group lI Packing group !!! Relative density × 0,5 m Relative density × 0,33 m NOTE 1 The use of these tests is optional. NOTE 2 The mark allocated to such packagings is not a UN mark but a RID/ADR mark. nake it clear to customers of light gauge metal packagings that they are forbidden as a single packaging outside the countrie: To avoid confusion packages marked with an RIDIADR mark should not include a UN mark. Manufacturers should f RID and ADR and they are not permitted on ships or aircrafi#

Page 52EN ISO 16104:2002 (E) Annex B (informative) Packaging types, codes and references B.1 Packaging types, codes and references • The packaging type definitions are given in the UN Recommendations and the various regulations. Tables B.1 give the appropriate references from each of the publications (full details are set out in the Bibliography). Table B.1 - Packaging definitions Packaging type UN Recommendations RID/ADR — IMDG Code- ICAO Tls Chapter 6.1 ICAO Steel drums 6.1.4.1 Aluminium drums steel Drums of metal other than aluminium or 6.1.4.2 6.3.1.1 6.1.4.3 6.3.1.2 6.3.1.3 Steel and aluminium jerricans Wooden barrels Plywood drums 6.1.4.4 6.3.1.4 6.1.4.5 6.3.1.5 Fibre drums 6.1.4.6 N/A Plastics drums and jerricans 6.1.4.7 6.3.1.6 Boxes of natural wood 6.1.4.9 6.1.4.8 6.3.1.7 Plywood boxes 6.1.4.10 6.3.1.9 6.3.1.8 Fibreboard boxes Reconstituted wood boxes 6.1.4.11 6.1.4.12 6.3.1.10 Plastics boxes 6.1.4.13 6.3.1.11 Steel or aluminium boxes 6.3.1.12 6.1.4.14 6.3.1.13 Textile bags Woven plastics bags 6.1.4.15 6.1.4.16 6.3.1.14 6.1.4.17 6.3.1.15 6.1.4.18 6.3.1.16 Composite packagings (plastics material) 6.1.4.20 6.1.4.19 6.3.1.18 6.3.1.17 Composite packagings (glass, porcelain or stoneware) Not permitted Combination packagings Light gauge metal packagings 6.1.4.21 RID/ADR only 6.1.4.22 RID/ADR only -#

Page 53EN ISO 16104:2002 (E) B.2 Relationship between Table B.1 and UN packaging codes Table B.2 shows the relationship between Table B.1 and the UN packaging code. NOTE Table B.2 may not cover every permutation and if in doubt advice from the competent authority should be sought. Table B.2— Relationship between Table 1 and UN packaging codes Column Description UN packaging codes that may be included in this A category Metal packagings for liquids 1A1, 1A2, 1B1, 1B2, 1N1, 1N2, 3A1, 3A2, 3B1, 3B2 2 Metal packagings for solids or inner packagings other than plastics 32 A2, 1, 102, 1, 12, 3A1, 3A2, 381, 3 Stas orangs for solids with plastics iner packagings (for 1A1, 1A2, 132, 1N2, 3A2, 382 4 Pasties packagings for solds or inner packagings other than 1H1, 1Н2, 3Н1, 3H2 5 pragues packagings with plastics iner packagings for solds 1H2, 3H2 6 Plastics packagings for liquids 1H1, 1H2, 3Н1, ЗН2 7 anagis packagings with a plastics inner for solds or inner SHAT, 6HA2, 6181, 6482, 6НС, 6401, 6HD2, 6HG1, 6HG2, 6HH1, 6HH2 8 Composite packagings with a plastics inner for liquids 6HA1, 6HA2, 6HB1, 6HB2, 6HC, 6HD1, 6HD2, 6HG1, 6HG2, 6HH1, 6HH2 Composite packagings (glass, stoneware and porcelain) 6PG1, 6PG2, 6PH1, 6PH2 6PA1, 6PA2, 6PB1, 6PB2, 6PC, 6PD1, 6PD 2 10 Fibre or plywood drums for solids or inner packagings other than plastics 1G, 1D 11 Fibre or plywood drums for solids with plastics inner packagings 1G, 1D 12 Plastics boxes for solids or inner packagings 4H1, 4H2 13 lead boxes for solids or inner packagings other than 4G 14 Fibreboard boxes for solids or with plastics inner packagings 4G 15 Other boxes for solids or inner 4A, 4B, 4C1, 4C2 packagings other than plastics 16 Other boxes for solids or with 4A, 4B, 4C1, 4C2 plastics inner packagings Bags (paper) 5M1, 5M2 18 Bags 5H1, 5H2, 5H3, 5H4, 5L1, 5L2 NOTE The letters "T, "V" and 'W" may follow the codes in the table e.g. "1A1W". Where applied these signify the following; "T" a salvage packaging see C.2 "m a special packaging see C. 1 down into packaging of the same kape indicated away d apured by the corp tent dulent petication than that set -#

Page 54EN ISO 16104:2002 (E) B.3 Comparision of all provisions able B.3 is intended to assist readers in comparing the provisions of this Standard with the requirements of th JN Recommendations and RID/ADR, ICAO TIs and the IMDG Code Table B.3 — Comparison of all provisions UN Recommendations CEN/ISO Reference RID/ADR ICAO TIs IMDG Code Performance and frequency of tests 6.1.5.1 6.4.1 6.1.5.1.1 6.4.1.1 5.1, 5.2 6.1.5.1.2 6.4.1.2 3.1, 4.1 6.1.5.1.3 6.4.1.3 Quality assurance Not part of standard 6.1.5.1.4 6.4.1.4 4.1 6.1.5.1.5 6.4.1.5 5.1, Annex D 6.1.5.1.6 6.4.1.6 Not part of testing 6.1.5.1.7 6.4.1.7 4.1, Annex C.1 6.1.5.1.8 6.4.1.8 Quality assurance 6.1.5.1.9 6.4.1.9 6.1.5.1.10 6.4.1.10 5.1 6.1.5.1.11 6.4.8 4.1 Annex C.2 Preparation of packagings for testing 6.1.5.2 16.4.2 6.1.5.2.1 6.4.2.1 15.3, 5.4, 5.5 6.1.5.2.2 6.2.2.2 15.3 6.1.5.2.3 6.2.23 Table 1(Col. 7, 12) 6.1.5.2.4 NIA Not addressed 6.1.5.2.5 6.2.2.4 Compatibility separate std see ENISO16101. Note: RID/ADR includes 6.1.5.2.6 — see ENISO16104 6.1.5.2.8 which refer to compatibility testing Drop test 6.1.5.3 16.4.3 77.1 6.1.5.3.1 6.4.3.1 17.1 Table 2 6.1.5.3.2 6.4.3.2 4.1 Table 1(Col 8 Notes 2, 5) 6.1.5.3.3 6.4.3.3 6.5 6.1.5.3.4 6.4.3.4 17.1.2#

Page 55EN ISO 16104:2002 (E) 6.1.5.3.5 16.4.3.5 6.1.5.3.5.1 6.4.3.5.1 4.2a) 6.1.5.3.5.2 6.4.3.5.2 7.1.7 6.1.5.3.5.3 6.4.3.5.3 4.2b) 6.1.5.3.5.4 6.4.3.5.4 4.2b) 6.1.5.3.5.5 6.4.3.5.5 (4.2a) 6.1.5.3.5.6 6.4.3.5.6 4.2b) Leakproofness test 6.1.5.4 16.4.4 17.3 6.1.5.4.1 6.4.4.1 14.1 Table 1(Col 14) 6.1.5.4:2 6.4.4.2 7.3.3 6.1.5.4.3 6.4.4.3 |4.1 Table 1(Col 15), 7.3.4, 7.3.5 6.1.5.4.4 6.4.4.4 14.4.2 Internal pressure (hydraulic) test 6.1.5.5 7.4 6.1.5.5.1 6.4.5.1 4.1 Table 1 (Col 16) 6.1.5.5.2 6.4.5.2 4.1 Table 1 (Col 16) 6.1.5.5.3 N/A 7.4.3 (7.3.3) 6.1.5.5.4 6.4.5.3 4.1 Table 1(Col 17) 6.1.5.5.5 6.4.5.4 17.4.4 6.1.5.5.6 N/A 7.4.1 Note 2 (Unique to Air) In RID/ADR and IMDG Code this is 6.1.5.5.6 6.1.5.5.7 6.4.5.5 4.5 Stacking test 6.1.5.6 16.4.6.1 14.1 Table 1 6.1.5.6.1 6.4.6.2 4.1 Table 1(Col 9) 6.1.5.6.2 6.4.6.3 4.1 Table 1 (Col 12, 13), 7.2 6.1.5.6.3 6.4.6.4 4.3 Cooperage test 6.1.5.7 N/A Not addressed Test report 6.1.5.8 16.4.7 Annex E (see note below) 6.1.5.8.1 6.4.7.1 Annex E 6.1.5.8.2 6.4.7.2 and 647.3 Annex E NOTE paragraph 6.1.5.9 Note in RID/ADR 6.1.5.8 addresses compatibility and is dealt with in EN ISO 16101 and the test report is in#

Page 56EN ISO 16104:2002 (E) B.4 Liquids a melting point or initial meiting point of 20°C or lower at a pressure of 101,3 kPa can be considered to be liquids. Unless there is an explicit or implicit indication to the contrary in the UN Recommendations, dangerous goods with A viscous substance for which a specific melting point cannot be determined should be subjected to the test in substances of any class. granules. The choice of tests for any packaging depends crucially on whether the design type is to be tested for liquids or solids. The substances packed in packagings include free-flowing liquids, pastes, viscous substances, powders and There is, however, no simple, absolute and natural distinction between the two. Moreover, some substances which are solids at say 20 °C become liquid at 55 °C which is the reference temperature for that which may be experienced in transport. General substances which may become liquid during a journey in b) and on phlegmatized substances in c). guidance on whether a design type should be tested for liquids or solids is provided in a) of this note with specific advice on a) As indicated, the UN Recommendations and the international agreements contain definitions making the distinction between liquids and solids from measurements of specific melting point or by penetrometer testing. Such measurements measurements. In most instances there will be little difficulty in choosing between testing for liquid or for solid contents. In are rarely necessary in relation to packaging testing which may be carried out in a facility not equipped to make such specific dangerous liquid to be carried. Similarly, a packaging will be designed for solids and tested using, for example, a many instances a packaging will be designed for liquids and tested using water as contents without reference to any circumstances it is appropriate for each user of the packaging to check that the testing has been suitable for the dangerous mixture of plastics granules and fine powder without reference to any specific dangerous solid to be carried. In such substance. In other instances, however, the design type tests for a packaging will be undertaken in relation to a specific dangerous substance; if that substance should be borderline between a liquid and a solid, then it is recommended that the appropriate data on it should be obtained before tests are selected and commenced. b) Packagings being tested for solids which are likely to melt during the intended journey should be tested as for liquids. c) Packagings being tested for solids which require phlegmatizing with a liquid for safe transport, such that there is free liquid • mixture of solids and liquids. in the packaging, should be subjected to the appropriate tests for liquids with the test contents being a representative#

Page 57EN ISO 16104:2002 (E) Annex C (normative) Special packagings C.1 "V" marked packagings C.1.1 Introduction The UN Recommendations provide for the use of a special packaging which will not be tested as prepared for C.1.2 Requirements C.1.2.1 Drop Test The outer packaging shall have been successfully tested in accordance with 7.1 with fragile (e.g. glass) inner packagings containing liquids using the packing group I drop height. C. 1.2.2 Stacking Test identical packagings shall be based on the combined mass of inner packagings used for the drop test. The outer packaging shall have successfully passed the stacking test in 7.2 while empty. The total mass of M. = (3000 0 - 1 xm where: My is the required mass in kg h is the height of outer packagings (in mm) m is the mass of packaging as drop tested in kg C.1.3 Selection and preparation of test packagings The provisions of 5.1 and 5.2 shall apply. The packaging shall be filled as follows: a) The inner packagings shall be of glass, porcelain or stoneware and the type and thickness of cushioning material shall be noted in the test report along with the number and arrangement of the inner packagings b) Inner packagings containing liquids shall be completely surrounded with a sufficient quantity of absorbent material to absorb the entire liquid contents of the inner packagings. c) If the outer packaging is intended to contain inner packagings for liquids and is not leakproof, or is intended to event of leakage shall be provided in the form of a leakproof liner, plastics bag or other equally efficient means contain inner packagings for solids and is not siftproof, a means of containing any liquid or solid contents in the of containment. For packagings containing liquids, the absorbent material required in b) above shall be placed inside the means of containing the liquid contents. d) the thickness and identification of the cushioning material (e.g. vermiculite) between inner packagings and recorded in the test report. between inner packagings and the outer packaging shall be measured and the relevant minimum thicknesses)#

Page 58EN ISO 16104:2002 (E) C.1.4 Test procedures The procedures set out in clause 7 of this Standard shall be followed. C.1.5 Test report A test report in accordance with annex E shall be prepared. NOTE Included in the test report there should be an additional calculation showing the gross mass permitted for this packaging type. The UN Recommendations require the total combined gross mass of inner packagings should not exceed one-half the determine the final mark. gross mass of inner packagings used for the drop testing. This information should be used by the competent authority to The calculation for the mark should be as follows: 1 where: M is the mass mark to be applied to the packaging in kg m is the mass of the outer packaging in kg p is the mass of the inner packagings including contents used for the drop test in Kg.^ The UN mark allocated shows that the packaging has been tested to packing group I level for combination packagings. Packagings tested under this procedure have a special marking which includes the letter "V". C.2 Salvage packagings ("T" marked packaging) C.2.1 Introduction Damaged, defective or leaking dangerous goods packagings, or dangerous goods that have spilled or leaked are transported in special salvage packagings. This does not prevent the use of a bigger size packagings of appropriate type and performance level tested in accordance with this standard. C.2.2 Requirements Salvage packagings shall be tested as follows: C.2.2.1 Drop test permitted to achieve the requisite packaging mass provided they are placed so that the test results are not affected The packaging shall be filled with water in accordance with 5.3.3. The addition of lead shot or other additives is (see 5.3.2.) The packaging shall be dropped in accordance with 7.1.3 from a height of 1,2 m. Alternatively the drop height shall be adjusted in accordance with 7.1.2.2.2. C.2.2.2 Stacking test The stacking test shall be carried out in accordance with the provision 4.3 and tested in accordance with 7.2. =.#

Page 59EN ISO 16104:2002 (E) C.2.2.3 Leakproofness test ressure to be applied shall be 30 kP he packaging shall be treated in accordance with the provision of 4.4 and tested in accordance with 7.3. Th C.2.3 Test procedures The procedures set out in clause 7 of this Standard shall be followed. C.2.4 Test report A test report in accordance with 4.6 and annex E shall be completed. Packagings tested under this procedure have a special marking which includes the letter "T".#

Page 60EN ISO 16104:2002 (E) Annex D (informative) Special test requirements D.1 Metal drums and jerricans and composites with a metal outer body In certain circumstances stacking tests can be waived when the test has been carried out on an equivalent design type. Stack testing is not normally required when the design type can be assimilated to a design type previously certified from the same manufacturer (referred to here as the "previous design type"). Compared with the previous design pe, the packagings being tested may have changes to the head and the base, including changes to closure roviding no closure is subject to stack loads, but should meet the conditions set out in a) to e) as follow a) the cross section should be identical and the height of packagings to be tested may be slightly less than that of the previous design type; b) the body construction should be identical. This includes general configuration e.g. seams, rolling hoops and corrugations; c) the body metal thickness should not be less than that of the previous design type; d) the stack load required should be equal to or less than the load for which the previous design type has been certified; e) test reports should contain the following wording in the results section on stack testing "already covered by made and the calculated load required for the packaging for which the new mark is being sought Test Reports) ******", together with a note of the applied load recorded in the report to which reference is#

Page 61EN ISO 16104:2002 (E) Annex E (normative) Test report and specifications E.1 Introduction Every test shall be accompanied by a test report, the contents of which are set out below. E.1.1 Test facility (name and address) paper of the test facility. If headed paper is not available the report shall be clearly traceable to the author and the This shall be the organization that undertook the actual testing. The front page of the report shall be on the headed test facility. E.1.2 Applicant (name and address) The applicant can be the manufacturer, the user of the packaging or any person in the packaging chain. NOTE In some instances the test facility and applicant address may be the same. E.1.3 Report number to the original test. The report number shall appear on every page of the report and any annexes. Any subsequent This shall be a number which enables full traceability back to the original test facility working documents that refer amendments shall include the number and clearly show it is an amendment to or an addition to the original report. E.1.4 Date This shall be the date the report was completed, rather than the date that testing was completed. The report shall also include the date of the start and completion of the tests and the date of receipt of test items. E.1.5 Manufacturer body of the report may not be necessary provided this is clearly stated in one of the annexes which can be clearly Because packaging specifications (see annex G) are a part of the report, the manufacturer's name in the main E.1.6 Packaging description manufacture (e.g. blow moulding). The description of the packaging design type (including dimensions, closures) shall include the method of The main report shall include a general description of the packaging. Full details of the packaging components and main report) or in the main report. A check for conformity with the relevant definition in the regulations shall be material shall be included either in the specification (see annex G) (provided there is a clear link between it and the included (see annex B). NOTE It may also include drawing(s) and/or photographs. E.1.7 Capacities in 3.4 in litres. For packagings for liquids, the test report shall include brimful (overflow) capacity in litres. For The test report shall include the nominal capacity and the maximum capacity (brimful/overflow capacity) as defined packagings for solids (including inner packagings and articles) the test report shall include the gross mass in kg. -#

Page 62EN ISO 16104:2002 (E) E.1.8 Test contents Characteristics of test contents, which shall include for example viscosity and relative density for liquids and bulk density, particle size for solids and angle of repose. E.1.9 Test description and results number which shall be documented. At least one packaging shall be weighed full or empty. The report shall identify the number of packagings. Each packaging sample shall have its own identification There shall be a description of each test and how it was performed. levels achieved, particularly hydraulic pressure for liquid packagings and the maximum gross mass and density for The report shall include a conclusion clearly indicating the packaging group to which the tests belong and the test combination packagings. Where a competent authority has agreed to deviations from the standard methods set out in this standard, reference to such authorization shall be included in the test report. E.1.10 Signature The test report shall be signed with the name and status of the signatory. the laboratory. That person might be the tester or his/her supervisor. The person who was responsible for the testing, shall sign the report against his or her typed name and position in The report shall include the following statements: "This packaging was tested as prepared for transport in accordance with the provisions of part 6.1.5 of Chapter 6.1 of the UN Recommendations in particular sections...... "The use of other packaging methods or components shall render it invalid. A copy of the test report shall be available to the competent authority. NOTE 1 The competent authority may require the test report to be retained for a specified period of time. NOTE 2 The competent authority may require the reference to relevant regulations E.2 Specification checking detail included in the check are marked with an asterisk in the tables in annex G. The test report shall include the results of the specification check by the test laboratory. Items which shall be below: Where further explanatory notes are given these are indicated by a letter in the tables in annex G and are listed A Thickness only shall be checked; B Combined grammage only shall be checked; S Technical data shall be checked. -#

Page 63EN ISO 16104:2002 (E) Annex F (informative) Selective testing F.1 General F.2Metal drums and jerricans packaging can meet the test levels in the weakest construction case using the same test medium, the criteria that When selective testing is undertaken in respect of a range of packagings, provided it can be demonstrated that the may be considered for metal packagings are as follows: a) variations in head design, e.g. convex or concave; b) variations in closure systems due to alternative suppliers, provided interchangeability criteria have been met; c) variations in the number of closures and their location in the drum; d) variations in material of closure plugs) e.g. steel or plastics plugs; e) minor variations in closures e.g. vent fitting; f) variation in gasket or washer materials of the closure(s) e.g. rubber or plastics; g) addition of pressed out beads with or without internal or external corrugations; h) variations in the thickness of ends; i) addition of filling and emptying devices (as closed for transport). F.3Plastics drums and jerricans for liquids drum and jerrican can meet the test levels in the weakest construction case using the same test medium, the When selective testing is undertaken in respect of a range of packagings, provided it can be demonstrated that the criteria that may be considered for plastics packagings for liquids, are as follows: a) variations in the number of closures and their location in the drum; b) variations in closure material; c) variations in closure types, e.g. plain, combination, vented, external or internal thread, etc; d) variations in overseal material; variations in gasket material; f) addition of fitted filling or emptying devices (as closed for transport); variations in panels where marks are embossed. -#

Page 64EN ISO 16104:2002 (E) F.4Plastics drums and jerricans for solids Where selective testing is undertaken in respect of a range of packagings, provided that it can be demonstrated the criteria that may be considered for plastics drums for solids, inner packagings or articles, are as follows: that the drum and jerricans can meet the test levels in the weakest construction case using the same test medium, a) variations in head material and design;- b) variations in closure systems due to alternative suppliers; c) variation in gasket or washer materials of the closure system; d) variations in the number of closures and their location in the drum; e) variations in overseal material. F.5Fibre drums the drum can meet the test levels in the weakest construction case using the same test medium, the criteria that When selective testing is undertaken in respect of a range of packagings, provided that it can be demonstrated that may be considered for fibre drums for solids, inner packagings or articles, are as follows: a) variations in head material and design; b) variations in closure systems due to alternative suppliers, provided interchangeability criteria have been met; c) variation in gasket or washer materials of the closure system; d) addition of lined barrier; e) minor variation in number of plies within sidewall, lid or base provided the minimum material thickness is maintained.#

Page 65EN ISO 16104:2002 (E) Annex G (normative) Packaging specifications G.1 Specification data specification. To assist in the identification of a packaging, following the issue of a test report, it is necessary to have a detailed for the identification of test packagings by users, test facilities and competent authorities. The attached table matrices, G.1.1 to G.5.2, correlate the different packaging types with data which are necessary There are five parts to this annex: 1) drums, jerricans, bottles, jars etc — Tables G.1.1 and G.1.2; 2) boxes — Tables Tables G.2.1 and G.2.2; 3) bags — Tables G.3.1 and G.3.2; 4) inner receptacles of composite packagings - Table G.4; 5) inner packagings of combination packagings — Tables G.5.1 and G.5.2. Tabe a an and a to pars The fit an are gly alped by are in hat agony. The Each item in the table is numbered and in G.2 at the end of this Annex there are explanatory notes for many of the numbers to assist in interpretation. laboratory): The following symbols relate to procedures in relation to checking specifications on completion of testing by the test *= item to be checked; A = thickness only; B = combined grammage; S = technical data. thicknesses. The specification check shall be done visually and, where relevant, by measuring main dimensions and The specification check data as measured on the test samples shall be recorded and compared with the design type specification including manufacturing tolerances. The measured data of the test samples should be within the stated tolerances.#

Page 66EN ISO 16104:2002 (E) Table G.1.1— Drums, jerricans, bottles and jars etc. — Packaging specification detail applicable to all No Specification check requirement • No Specification check requirement 1 trade name Packaging description (code and 17 Closure(s), (or neck(s)) position(s) * 2 Manufacturer's name and address 18 Closure(s), material(s) and grade 3 Method of construction 19 Closure(s), type, identification 4 Nominal capacity 20 Closure(s), thread, type and pitch 5 Brimful capacity 21 Closure(s) mass 6 internal Diameter, nominal (cylindrical) 22 Closure manufacturer's name and address Diameter, external at widest point * 23 Closure torque(s) 8 Nominal diameters (conical i.e. pails) 24 Type of overseal * 9 Body/section dimensions (non-round) * 25 Closure(s) seal, material * 10 Recess of ends * 26 Neck internal diameter * 11 Height overall * 27 Height to neck face * 12 Stacking height * 28 Neck height (external) 13 End seams type * 29 Neck thread, type and pitch * 14 Side seam type * 30 Neck thread number of starts 15 Handles, material type, number and position * 31 Tare mass * 16 Closure(s), diameters) and design#

Page 67EN ISO 16104:2002 (E) Table G1.2 — Drums, jerricans, bottles and jars etc — Packaging specification detail applicable as indicated No. Specification check requirement Non-removable head metal Removable head metal Non-removable head plastics Removable head plastics Glass and other materials Fibreboard Plywood 32 Nominal thickness and material type and grade head or lid "A 33 Nominal thickness and material type and grade *A 34 *A : Nascinal thickness and material type and grade 35 Material type, grade (polymer) body 36 Material type, grade (polymer) base 37 Material type, grade (polymer) lid/head 38 Material lid gasket co co 39 Body corrugations, number * S 40 Body corrugation, heights 41 Rolling hoops, number, height and location * 42 Closing ring type Closing ring material 44 Thickness closing ring Number of plies (body) 46 Grammage per ply body, and combined *B Inner lining or coating material S Chime reinforcement S 49 Method of lid retention (other than closing ring) S s 50 Mass body * No combined grand or shai le atone (5 6), - required ais for that packaging typication check (se 0.2);#

Page 68EN ISO 16104:2002 (E) Table G2.1— Boxes packaging specification detail — Applicable to all No Specification check requirement I 1 name) Packaging description (code and trade 2 Manufacture's name and address 51 Design standard, drawing, or style * 3 Method of construction 31 Mass empty box 52 Dimension external (1 xb x h) • 9 Dimension internal (1 x bx h) 12 Stacking height * 15 Handles, material type, number and position 53 Closures, number, type, position and materials * 54 materials Reinforcements, type, position and * NOTE 1xbxh his length, breadth, height#

Page 69EN ISO 16104:2002 (E) Table G2.2— Boxes packaging specification detail — Applicable as indicated No. Specification check requirement Plywood and reconstituted wood Natural wood Expanded plastics Metal Fibreboard Plastics Material lid gasket S S Material ends 32 Nominal thickness, material type and grade head or lid *A S Nominal thickness, material type and grade side walls *A S S S Nominal thickness, material type and grade base *A S S S 56 Method of joining panels * S Manufacturer's join body * 58 Grammage by paper and paper type * 59 Corrugated flute type Corrugated combined grammage * S 61 Corrugated edge crush * 62 Burst strength S 91 Puncture 35 Material type, grade (polymer) body 36 Material type, grade (polymer) base 37 Material type, grade (polymer) lid 63 Density 64 Top flap inner gap or meet S 65 Top flap outer meet or overlap 66 Bottom flap inner gap or meet 67 Bottom flap outer meet or overlap S Notined grating o shai i checked (ce 52) - required data to that packaging typecification check (see G.2); B= •#

Page 70EN ISO 16104:2002 (E) Table G3.1— Bags packaging specification detail — Applicable to all No Specification check requirement 1 Packaging description, (code and trade name) 2 Manufacturer's name and address 4 Nominal capacity 51 Design standard or drawing 5 Method of construction 68 Style 52 Dimensions flat unopened 69 Gusset, open width 70 Bottom width, flat unopened 71 Valve width * 73 Closure method (top, base, side) * 74 Perforations 75 Sewing, style and density of stitches * Type of thread and minimum breaking load 77 Filter cord 78 Adhesive, type#

Page 71EN ISO 16104:2002 (E) Table G3.2— Bags packaging specification detail — Applicable as indicated No. Specification check requirement Unlined/uncoated woven plastics Other woven plastics Unlined/uncoated textile Plastics film Other textile Paper 32 Material type and grade S 35 Type of film grade 33 Nominal thickness, material type and grade *A. 79 Fabric (warp/weft), tapes per 100 mm * S S S S 82 Coating, material, thickness/weight S S S 83 Liner, material, thickness * S S S 45 Number of plies * S Grammage of plies * S S S 84 Material strength elongation S S S 85 Material strength tensile (energy absorption) NOTE heck (see G.2); B = combined grammage shall be checked (see G.2), S = required data for that packagin = required on specification checks (see G.2); A = thickness to be measured for specificatio Table G4— Inner receptacles of composites packaging specification detail — Applicable to all No. Specification check requirement 1 1a Description 2 Manufacturer's name and address 4 Nominal capacity 5 Brimful capacity 30 Material type and grade 32 Nominal thickness body "A 33 Nominal thickness base *A 34 Nominal thickness head *A 31 Tare (mass) * 86 Assembler of complete container -#

Page 72EN ISO 16104:2002 (E) Table G5.1— Inner packaging of combination packaging specification detail - Removable fittings No. Specification check requirement 30 Material type (and grade) 1 Description 51 Design standard or drawing 87 Quantity or number * 52 Dimensions 27 Tare mass * 32 Nominal thickness * 58 Grammage by paper and paper type 60 Corrugated combined grammage *B 90 Orientation and arrangement of inner Packagings Table G5.2— Inner packaging of combination packaging specification detail — Permanent fittings No. Specification check requirement 1 Description 30 Material type and grade 51 Design standard or drawing 87 Number 88 Location(s) 89 Means of fixing to packaging ickness to be measured for specification check (see G.2); B Required on specification checks (see G.2); A for that packaging type. combined grammage shall be checked (see G.2); S = required data#

Page 73EN ISO 16104:2002 (E) • G.2 Notes to packaging specification detail applicable to Tables G.1 to G.5.2. 1. Packaging description i.e. steel drum, code where appropriate i.e. 1A1 (see Table B.2) and trade name. 2. Name and address of manufacturer of packaging or appropriate component. 3. Method of construction i.e. welded; glued and stitched; nailed etc. 4. Nominal capacity: see 3.4.2. 5 Brimful capacity: see 3.4.1. 8. Smallest and largest for conical shaped packagings. 9. For non-circular packagings. 10. Usually found on drums. 11. From ground to highest point, however the dimensions may be less than that specified in the test report. 12. Adjusted height to allow for any interlocking features of packaging; may also include battens on boxes. 13. Where applicable. 14. Where applicable. 15. Also indicate if an optional extra. 16. Required for each closure and variant. 17. Position on drum. 18. Required for each one and variant, including plastics polymer details. 19. May include trade name and any features or marks on closure. 21. Mass of individual closure with gasket/wad. 22. For each closure. 23. For each closure. 24. If fitted. 25. Gasket details. 31. Mass of container and closures and associated fittings. 32. All materials other than plastics. 33. All materials other than plastics. 34. All materials other than plastics. 35. Plastics materials only. 36. Plastics materials only. 37. Plastics materials only. 38. When lid or head fitted with gasket, washer or seal. 46. Combined grammage will include an allowance for the glues between the paper plies. 49. To allow for large screw caps, pill box lids, etc. 50. Particularly plastics. 51. Include FEFCO/ASSCO code for fibreboard boxes if applicable. 53. This is to include taping patterns and any additional means of closing such as straps. 54. Battens, corner posts etc. 68. Valved, gussetted etc. Some of this may be covered by 1. 86. This may not be the same as any of the manufacturers of the parts of a composite packaging.#

Page 74EN ISO 16104:2002 (E) Bibliography Standards publications EN 22234, Packaging — Complete filled transport packages - Stacking test using static load (ISO 2234:1985) EN ISO 9001, Quality management systems — Requirements (ISO 9001:2000) EN ISO 12048, Packaging — Complete filled transport packages — Compression and stacking tests using a compression tester (ISO 12048:1994) prEN ISO 16101, Packaging - Transport packaging for dangerous goods - Plastics compatibility testing (ISO/DIS 16101:1999) ASTM-D-4359-90, Test methods for determining whether a material is a liquid or a solid. Other documents The UN Recommendations have been developed by the United Nations Committee of experts on the transport of dangerous goods, in the light of technical progress, the advent of new substances and materials, the exigencies of Amongst other aspects, the recommendations cover principles of classification and definition of classes, listing of modern transport systems and, above all, the need to ensure the safety of people, property and the environment. and shipping documents. There are in addition special recommendations related to particular classes of goods (in the principal dangerous goods, general packing requirements, testing procedures, marking, labelling or placarding, particular Explosives). international inconsistencies in application. This standard gives guidance with respect to uniform interpretation and Though written in technical terms, the testing procedures still include areas of interpretation which may lead to application of the UN testing procedures. The following regulations are referred to in the text of the standard. Each edition is revised regularly and the latest one should be used. Test facilities should be in possession of at least one of the documents or alternatively their national law where it includes the relevant UN provisions. [1] The United Nations Recommendations on the Transport of Dangerous Goods - Model Regulations. ST/SG/A.C. 10/1/Rev.12. Geneva Geneva: United Nations, 1997, ISBN 92-1-139074-5. 12] The European Agreement Concerning the International Carriage of Dangerous Goods by Road (ADR) Geneva: United Nations 1999, ISBN 92-1-139070-2 and ISBN 92-1-139071-0. [3] Regulations Concerning the International Carriage of Dangerous Goods by Rail (RID). Berne: Organisation intergovernmentale pour les transports ferroviaires (OTIF), 1999. 14] International Maritime Dangerous Goods Code (IMDG). London: International Maritime Organisation, ISBN 92- 801-5090-1. 15] Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICAO TI/2001/2002). DOC 9284. AN/905. Montreal: International Civil Aviation Organization The directives of the European Community require the member states to apply the provisions of RID/ADR to all dangerous goods traffic in their territories: Council Directive 94/55EC on the approximation of the laws of the Member States with regard to the transport of dangerous goods by road. OJ L319. Council Directive 96/49EC on the approximation of the laws of the Member States with regard to the transport of dangerous goods by rail. OJ L235. -#

Page 758501 Moller Road Inland Paperboard and Packaging, Inc. • 3178.60 Testing 12-012* April 12, 2002 INLAND A Temple-Inland Company Mr. Edward Mazzullo, Director Office of Hazardous Materials Standards 400 7* St. SW U.S. DOT/RSPA (DHM-10) Washington, D.C. 20590 --- Dear Mr. Mazzullo: Thank you for discussing the questions I had about 49 CFR, 178.601(g)(2), Selective testing of combination packagings, Variation 2. It has been a little while since we had our phone conversation, so let me re-state the question to you for an official Letter of Interpretation. My company has a customer who manufactures liquid chemicals. In the certification in question, the chemicals are packed in plastic bottles. The bottles are of different shapes, and do not conform to Variation 1 requirements. The customer wants to test the packaging to Variation 2. In 178.601(g)(2)(i) it states that "The outer packaging must have been successfully tested in accordance drop height". Our customer has interpreted "e.g." to mean "for example". They requested that we test to with [part] 178.603 with fragile (e.g. glass) inner packagings containing liquids at the Packing Group I Variation 2 using their plastic containers, because at 0°F plastic is fragile as well. In our phone conversation, I learned that the statement about the use of fragile material such as glass was directed more toward brokers, because they sell certified boxes to various customers who may use any kind of inner packaging. As we discussed, an individual customer like ours, who plans to use nothing more fragile than the plastic containers that are tested, could be allowed to certify to Variation 2 by testing with the plastic containers. Is this indeed acceptable? In a situation such as this one, assuming that we can test to Variation 2 as discussed above, should a statement be included in the certification report such as: "The packaging qualifies under Section 178.601(g)(2) for selective testing of combination packagings as long as no inner packaging more fragile than plastic at 0°F is used." Would a statement like this satisfy the requirements of that section, or is it necessary at all? I look forward to your response. Thank you for your help. Sincerely, John I. Rutherford iohn H. Rutherford Manager, Testing Solutions Lab Inland Paperboard and Packaging Indianapolis, IN#

Page 76• JOHN H. RUTHERFORO Inland Paperboard and Packaging, Inc. Indianapolis, Indiana 46268 8501 Moller Road INLAND A Temple-Inland Company Mr. Edward Mazzulls Derector, Office of Hazardo U.S. DOT/RSPA (DHM -1 400 ?TH ST. SW Wadington, D.C. 20590#

Page 77John H. Rutherford Manager. Testing Solutions Inland Paperboard and Packaging, Ine. 8501 Moller Road Indianapolis, Indiana 46268 Phone 317.875.4130 Fax 317.875.4145 c-mail jruther@icenet.com INLAND A Temple-Inland Company#