Why can’t I get just: A ‘UN 4G BOX’?
Where can I get a ‘UN 4g box’?
’4G’ is a dangerous goods packaging code designator for a fibreboard box. It is primarily a handling device, known as the ‘outer packaging component’ of a combination package used to contain ‘inner packagings’ that contain dangerous goods. Although it provides some protection for the inner packaging’ its primary use is for ease of handling small bottle, cans, jars, etcetera. A ’4G box’ on its own is NOT a dangerous goods approved package. The supplier, the shipper, the freight forwarder, the airline operator and the ultimate user should be very aware of this otherwise they may find that they are shipping dangerous goods illegally with no recourse before the law. In the event of an incident. Milton T.Y Cassidy sums it up in an article published in the New Zealand D.G. News – July 1994.
“The important thing to realise is, that … a ‘UN 4G’ is not a box but a package – only one component of which is the fibreboard box. the application of the UN 4G markings to the fibreboard outer packaging constitutes a legal certification on the part of the person applying the markings that the completed package, (not just the fibreboard outer packaging), meets all applicable provisions of the UN 4G standard. Thus, without knowing the exact configuration of the completed package, a box manufacturer alone, is in no position to apply the required UN 4G markings – and to do so is a violation of theInternational Code for Air Transport (ICAO) Technical Instructions.
Combination Packaging is packaging consisting of an ‘outer packaging’ (e.g. a fibreboard box or a wooden box – ['4D'] into which is placed one or more ‘inner packaging’ (e.g. glass, or plastic, bottles, [or metal cans] etcetera) the most commonly used combination packages are those employing a fibreboard box as ’4G’ packaging.
Under the UN (Recommendations for the Transport of Dangerous Goods) packages must be performance tested “exactly as prepared for transport.” In the case of combination packages – this means the completed package, including all inner packaging’, cushioning material and all other components, must be subjected to the performance tests as an assembled unit, in the exact configuration that will be used for transport purposes. Such testing of the completed package is [not always] within the capabilities of the fibreboard manufacturer – at least without very close co-operation between suppliers of the outer packaging.
In New Zealand only a TELARC organisation can carry out this testing. [In Australia, only a NATA accredited package testing laboratory can carry out this testing]. for these reasons it is not anticipated that these types of packaging’ will be widely available ‘off-the-shelf’ items. The concept inherent in the UN system of testing and certifying a package “prepared as to be used in transport” makes it impossible to call a fibreboard box manufacturer and simply order a “4G box”.
Instead, combination packaging components such as inner packaging, the outer fibreboard box, cushioning materials, caps, gaskets or seals, tape for closing the assembled box, etceteras, will probably be purchased from different suppliers. In the end, someone will be responsible for assembling these components into the completed package and then to test, mark and certify the package as complying with the ‘UN 4G’ standards. More likely than not, the person undertaking this responsibility will not be the manufacturer of the fibreboard box used in the outer package.
One element of the UN 4G markings that is required to be applied to the outer package is “the name and address or symbol of the manufacturer.’ Regardless of who did what in the packaging assembly, testing and certification process, the authorities normally view the [company] whose name appears in these markings as the ‘manufacturer’ and, therefore, the company certifying compliance with the UN. If the package is found not to be in compliance with the applicable requirements for one reason or another, it will be the company identified by these markings as the package ‘manufacturer’ that will be asked, at least initially, by the authorities to provide an explanation. It is for this reason that any person [company] particularly a fibreboard manufacturer, that applies UN 4G markings of the completed package to a box without full and complete knowledge of the final configuration and performance capabilities, is simply asking for trouble.
Packaging manufacturers must be certain that anyone assembling their packaging, whether employees of their own company or not, know exactly how the assembly is to be performed. This will ensure that each production package is identical, (including manner of closure, amount and type of insert or cushioning material, etcetera,) to the packaging used in the design [safety] qualification tests. Packages’ that deviates from the certified ‘design’ type’ are not allowed to be transported without testing, except as authorised under certain selective testing variation as identified in the ICAO Technical Instructions [and the IATA Dangerous Goods Regulations].
…So, if a fibreboard box manufacturer or packaging retailer tells you they can sell you an outer box, marked with the ‘UN 4G’ markings, be sceptical, ask questions, go elsewhere. There is a lot more to it than just marking ‘UN 4G’ on the box. Make sure the supplier understands what he [/she] is really offering and that you understand what he [/she] is really giving you.
Suppliers of fibreboard boxes and their customers, must realise that the combination packages must be tested, certified and marked “as prepared for transport” to ensure the safe carriage of dangerous goods and compliance with the regulations.
What Mr Cassidy does not emphasise in his editorial is that Inner Packagings of combination package, must also be packages separately tested and certified. So… read up on
WHAT ARE INNER PACKAGINGS?
What is: A PACKING GROUP?
As well as a the nine different ‘Class’ designators indicating the type of hazard a dangerous goods presents, a ‘Packing Group’ is assigned to dangerous goods according to the degree of hazard they present. These are as follows:
Packing Group I = Great danger
Packing Group II = Medium danger
Packing Group III = Minor danger
Classes 3 and 4, Divisions 5.1 and 6.1 and Class 8 and some Class 9 substances have Packaging Groups assigned to them. Packing Groups are not assigned to Class 1 ‘explosives’; Class 2 ‘gases’ and ‘gas mixtures’; Class 6.2 ‘infectious substances’ or Class 7 ‘radioactives.’ Packaging Group designators are always written in Roman numerals.
When performance testing a dangerous goods package in order to determine that the design of the package meets the minimum performance criteria required by the UN, and to attain the mandatory UN approval, the Packaging Group of the product to be transported in the package is one of the factors that determines the test protocol. Testing conducted on a package for a P.G. I product is considerably more stringent than the testing requirements for a P.G. III product.
What is the difference between: A CLASS 6.2 PACKAGING SYSTEM and A 650 PACKAGING SYSTEM ?
In the design requirements, there is no major difference between Class 6.2 and 650 packaging systems. The two main differences are:
The test regime for 650 packaging is less stringent than for Class 6.2. The inner packagings of 650 systems must be tested separately with the same conditioning and test requirements as Class 6.2 design types but the packaging system “prepared as to be used in transport” needs only to undergo a Drop Test from 1.2 metres.
650 packaging systems need to be laboratory certified and meet the IATA specified design and package marking requirements and must be tested in accordance with the Regulations, but they do not need to bear UN approval markings and therefore do not require Competent Authority approval.
What is: A ‘LIMITED QUANTITY PACKAGE’?
‘Limited Quantity’ packages are a packaging type designated by the IATA Dangerous Goods Regulations as being acceptable for some products of some hazardous goods ‘Classes’ and some ‘Packing Groups’ that contain very small quantities of dangerous goods. IATA Packing Instructions for these products are always preceded by ‘Y’ .
When choosing packaging to air freight your products in Limited Quantity packages, ensure that the airline operator and the country of destination accept Limited Quantity packages Some airlines and some countries do not. Some airlines and some countries may accept them for some products and not for others. Some countries may not allow such packaging’ to “pass through” even if that country is a transit stopover and not the final destination. Some countries may accept limited quantity packages but they will not allow on-forwarding by air on domestic airlines. They will be on-forwarded only by road.
The minimum legal requirements for Limited Quantity packages (IATA DGR 2.7) is that they must meet “the general packaging requirements of Division 5.1. In particular:
Inner packagings of Limited Quantity packages must have been separately tested in accordance withClause 126.96.36.199 of the IATA Dangerous Goods Regulations; that is, an internal pressure test to not less than 95 kPa but to not less that the pressure differential at 500C of the product to be transported, or whichever is the greater.
- Packages must be packed in compliance with the specific ‘Y’ packing instruction.
- Packages must be compliant with Subsection 6.1 and 6.2 of the IATA Dangerous Goods Regulations
- Packaging’ must comply with the test requirements of 6.6 of the IATA Dangerous Goods Regulations
The design type package must be prepared exactly as to be used in transport and must survive without any loss of contents, leakage or breakage:
- A Drop Test of 1.2 metres onto the most vulnerable point of the package
- A Stacking Test equivalent to a 3 M high stack of similar packaging’ for 24 hours
The main difference between a ‘UN approved’ combination package and a ‘Limited Quantity’ packaging is that the limited quantity package test requirement is less stringent.
The Limited Quantity package in its combination format, with inner packaging(s), and outer and any other components, does not have to be approved by the Competent Authority and therefore does not need to carry UN package specification and approval markings on the outer package.
What is: AN ‘EXCEPTED QUANTITY’ PACKAGE ?
Excepted Quantity packages may be used to transport some chemicals of some Packing Groups. Inner packagings of Excepted Quantity Packages do not have to be approved or performance tested provided that all the provisions of Subsection 2.6 are met and that the following requirements are also met:
- The training requirements of 1.5
- The definitions in Appendix A
- The classification provisions in Section 3
- The loading restrictions in 9.3.1
- The reporting of accidents and incidents in 9.5
The packaging requirements are as follows:
- Inner packaging must not contain more than the hazardous Class and Packaging Group limitations on the product and may NOT be mixed with inner packaging’ of a Class or P.G. not covered by the exceptions as per Table 2.6.A of the IATA D.G. The Lists of 4.2 Regs.
- Outer packages must not contain more than the hazardous Class and Packaging Group limitations on the product.
- Incompatible products may not be packed together in one package.
- Entire liquid contents of the inner packaging.
- The intermediate packaging containing the inner packagings must be packed into a rigid outer packaging of strong material.
- At least two of the sides of the outer packaging may not be less that 100 mm in width and length and cylindrical packages may not be less than 100 mm in diameter or less than 100 mm in height.
- All packaging component materials must be compatible with the product.
- Plastic inner packagings must have a minimum thickness of 0.2 mm. Closures of inner packagings must be held securely in place with wire, tape, or other positive means.
- Inner packagings with screw closures must have “leak-proof” closures, that is, closures which will pass a 95 kPa inner pressure test without leakage at 550C.
- Inner packagings must not be filled to more than 95% of brimful capacity.
- Inner packagings must be packed in an intermediate packaging with absorbent cushioning material sufficient to absorb the package prepared as for transport must be capable of withstanding without breakage and leakage:
- Drop tests in six different orientation for boxes and 3 orientations for cylindrical packages from a height of 1.8 metres
- An applied force to the top of the package equivalent to a 3 metre stack height for a duration of 24 hours stack test.
PROVIDED THAT ALL OF THE ABOVE PROVISIONS ARE MET, SHIPPERS DECLARATION OF DANGEROUS GOODS NEED NOT ACCOMPANY THE PACKAGE except LTD.QTY.
What is: THE ‘IATA DANGEROUS GOODS REGULATIONS’ ?
The International Air Transport Association (IATA) Dangerous Goods Regulations are published byIATA “to provide procedures for the shipper and the operator by which articles and substances with hazardous properties can be safely transported by air on all commercial transport.” They are based on the International Civil Aviation Organisation (ICAO) Technical Instructions for the Safe Transport of Dangerous Goods by Air as the minimum legal requirement. These are in turn based on the UN Recommendations for the Transport of Dangerous Goods.
Most commercial airlines in Australia are affiliated with IATA and they must comply with the IATA Dangerous Goods Regulations that is regulated by ICAO and are more stringent in their requirements than ICAO . All other air craft operators, commercial and civil, are regulated by ICAO.
” The shipper is responsible for all aspects of the packing of dangerous goods in compliance with these Regulations”
IATA Packing Instructions outline:
HOW the dangerous goods must be packed; (that is, the packaging design requirements and the quantity limitations on the product).
Section 5 details: WHAT packaging conditions are required and WHERE and WHEN they are required.
Section 6 details: The tests that are to be applied to different types of packaging.
What are: AUSTRALIA POST’S REGULATIONS FOR THE TRANSPORT OF DANGEROUS GOODS…?
It is illegal to send dangerous goods in the post with the exception of infectious substances. Packaging requirements are the same as required by IATA and must be transported in UN approved packaging. Very small quantities of some minor hazardous substances may also be permitted in some circumstances provided that prior arrangements have been made with Australia Post and the packaging of the product conforms with their requirements.
For the surface transport of infectious substances some states and Australia Post have adopted theIATA Dangerous Goods Regulations as the minimum legal requirement. Australian Standard AS 2243 – Safety in Laboratories Part 3 – Microbiology states that when transporting infectious substances and potentially infectious substances quarantine and governmental regulations must be complied with including quarantine, postal and IATA regulations.
What is: AN ‘UN’ APPROVED PACKAGE ?
In Australia a ‘UN approved package’ is a package that has been designed and tested “prepared exactly as to be used in transport” without failure of performance in accordance with the requirements of the ADG Code; the ICAO Technical Instructions (or the IATA Dangerous Goods Regulations or the IMDG Code (seafreight regulations). This procedure ensures the package is a suitable and safe packaging for the transport of dangerous goods and that it is registered and therefore fully traceable.
The components that constitute a package ‘design’ can include components such as:
- Method and materials of construction;
- Type of sealing mechanism and closure;
- Dimensions, weight and capacity;
- Whether it is for transport of liquids or solids;
- A tested and certified inner packaging with the closure (cap or lid) with which it has been tested and certified for combination packages;
- An intermediary package for combination packages;
- An outer packaging for combination packages;
- The type of inserts which hold the inner inside the outer in a stable position (if required) for combination packages;
- Absorbent/cushioning material for combination packages;
- The internal configuration of the packaging components (how placed) the closing tape with which the outer packaging may be sealed and the manner of sealing (method of closing) for combination packages;
All types of packaging are subjected to their relevant test regime. After testing of a package, or inner packaging by a NATA accredited test laboratory, if the package passes the test program specific to it, a Test Certificate is issued by the laboratory that has performed the tests which then applies to the Dangerous Goods Competent Authority for its registration, the issue of an approval certificate and approval number for the package. The approval, together with the UN Test Certificate details the manufacturing specifications of the package and the terms and conditions under which the approval is issued and to what manufacturer(s)
Any changes made to any of the design features of a package, whether to a single package, an inner packaging, or to a combination package, including the shape of the inner packaging, dimensions of inners or outer, or to the inner configuration, can change the dynamics of the combination package and failure of the package or packaging can occur. Without testing there is no guarantee of performance or confidence that the package is “safe”. As it must be proven to be of equivalent performance , any design variants must be re-tested and a new approval submission made to the Competent Authority.
What is: AN ‘IATA CLASS 6.2 or 602 PACKAGE’ ?
It is a package that has been designed, tested, and approved for the safe transport and handling of ‘any human or animal material including, but not limited to, excreta, secreta, blood and its components, tissue and tissue and tissue fluids’ [whether in a solid, liquid, or frozen state] being shipped for the purpose of analysis or diagnostic testing where that substance is known to contain or may be suspected to contain an infectious substance.
It is the view of the Australian Competent Authority http://www.ntc.gov.au/viewpage.aspx?documentid=919 an infectious substances package supplied to the shipper without a performance tested primary receptacle, or, without specific written instruction on what primary receptacles it is approved to transport, and in what configuration they must be packed, is in breach of dangerous goods regulations.
If any doubt exists that a package bearing UN Class 6.2 package specification and approval markings does not meet Australian requirements, a copy of the Laboratory Test Report and the Competent Authority Approval can be requested from the supplier. The package supplied must match the specifications and details of the test report and the official Approval exactly.
What are the basic design & test requirements for: AN ‘APPROVED INFECTIOUS SUBSTANCE PACKAGES’ ?
An approved 602 package is a packaging system that meets all the mandatory design and test requirements. The Australian Competent Authority reject any approval submission if a test program has not been conducted on a package prepared exactly as it is to be used in transport . That is, with its secondary packaging(s) and primary receptacle(s) in a specific configuration, (number and position), in an upright stable position inside the package together with any other packaging components. The basic design elements for infectious substances packages as detailed in IATA Packing Instruction 602 requires that the basic package design has as a minimum:
- A water tight primary receptacle;
- A watertight secondary receptacle;
- Absorbent material between the primary receptacle and secondary packaging,
- The outer pack must be at least 100 mm (4 inches) in the smallest overall dimension
- Either the primary receptacle or secondary packaging must be capable of withstanding without leakage a pressure differential of not less than 95 kPa (13.8 lb/in2) in the range -400C to +550C (-400F to 1300F).
The complete packages, “prepared exactly as to be used in transport” are required to be subjected to the following test program and each sample tested is required to survive WITHOUT LEAKAGE FROM THE PRIMARY RECEPTACLE:
- A Drop Test in various orientations from a minimum height of 9 metres, ( 27 feet). Depending on the materials of the primary receptacles the packaging system may need to be conditioned prior to testing to -180C and then subjected to the all drop test orientations and again Drop tested after being subjected to “rainfall”.
- For packaging systems where infectious substance need to be transported in dry ice, this test must be repeated when the dry ice has completely dissipated in one orientation only.
- This is followed by a Puncture Test. A 7 kilogram profiled dart is dropped in two different orientations from a height of one metre onto the package and aimed to penetrate the inner packaging(s).
In addition to the above, in Australia, separate testing and approval of secondary packaging’ and primary receptacles is required.
What are: ‘INNER PACKAGINGS’ ?
As well as the combination package test requirements “prepared exactly as to be used in transport”in Australia, for road and rail transport, inner packagings of combination packages whether used to contain liquids or solids, must be separately tested and certified. For airfreight, inner packagings for liquids must be subjected to an internal pressure test. In Australia, the Competent Authority will not issue UN package markings and an approval to a combination package that does not contain separately tested and certified inner packagings. Combination packages may NOT contain:
- Inner packagings that have not been performance tested and certified;
- Inner packagings that have not been tested with the outer packaging “prepared as to be used in transport”
- Inner packagings where the closure (cap) is not the same one with which it has been tested and approved ;
- More inner packagings than the number with which it has been tested;
- Inner packagings larger in size than those tested in the combination package;
- Inner packagings containing liquids if the inner package has only been tested for solids;
- Inner packagings containing liquids if the combination package has only been tested for solids;
- Inner packagings packed in a configuration that is different to those originally tested;
- Packaging of a material other than for what the inner packaging and the outer packaging have been tested with. (e.g. if tested with metal packagin’ it may not be used to contain glass or plastic packaging; of if tested with plastic packaging may not be used to transport glass or metal inner packaging’ etcetera);
- Inner packagings that contain products that have a higher specific gravity than that at which the combination package has been tested;
- Inner packagings that contain products of which the vapour pressure is higher than that at which the inner packaging has been tested;
- Paint cans (removable head cans) (as they generally cannot pass the minimum internal pressure differential test requirement without some means of a firmly securing the lid)