Performance packaging that doesn't perform!

By John V. Currie -- Logistics Management, 6/1/2000

The United States adopted the United Nations Performance-Oriented Packaging Standards (U.N. POP) more than a decade ago to replace the old Department of Transportation (DOT) specifications. The packaging industry welcomed the flexibility granted by the U.N. standard, which permits innovative designs as long as they perform satisfactorily to specific testing criteria.

Some national governments conduct testing and provide certifications for packagings that successfully pass those tests. The United States permits the packaging manufacturer to submit testing samples to the DOT's Associate Administrator for Hazardous Materials Safety (AAHMS) but also authorizes self-testing by the manufacturer or third-party testing laboratories.

In order to "ride herd" on the nongovernmental testing facilities, the AAHMS can at any time require those facilities to verify the conduct and results of tests they performed that resulted in a packaging's receiving a U.N. Standard marking. A few years back, the DOT exercised that authority, contracting with the U.S. Army Material Command's Logistics Support Activity Package, Storage, and Containerization Center (LOGSA) in Tobyhanna, Pa., to purchase packagings from various vendors and retest them.

In the first four years of the contract, LOGSA tested 120 different U.N. Standard-certified packaging designs, including single packagings such as steel, plastic, and fiberboard drums; jerricans; and composite packagings, as well as some combination packagings with various inner receptacles in fiberboard boxes.

Of the 120 packagings tested, only 27 designs successfully passed the required tests. More than 77 percent experienced failure in at least one test mode, and many of them experienced multiple test-mode failures. The most vulnerable packagings appeared to be the open-head 1A2 drums, with 84 percent of brand new drums failing. LOGSA also tested seven open-head reconditioned drums, and not a single one passed the required tests. Of the 17 closed-head 1A1 drums, only one-third passed all the required tests. Investigators also found that the incidence of failures in drop tests, leakage tests, and hydrostatic tests by drums marked for "extreme certifications" were alarmingly high. Yet all of these packagings had been certified as being safe for use by a shipper within the marked limits!

In fairness to the packaging manufacturers, we must point out that the packagings that were tested at Tobyhanna were not randomly selected. The Office of Hazardous Materials Enforcement (OHME) targeted packagings that were marked as certified for the Packing Group I performance level ("X") with a high specific gravity or internal pressure. Users' complaints of packaging failures also influenced which packagings were chosen for testing.

In light of the test results, we strongly recommend that you obtain the certification paperwork for your packagings. You should also avoid using what the DOT describes as "macho packaging"-packaging marked for extremes in weight or pressure and marketed as a one-size-fits-all packaging solution.

OHME's Douglas Smith, who heads up the Tobyhanna project, says his agency has initiated 33 enforcement cases as a direct result of these packaging tests. So far, 13 cases have already been closed with penalty, which resulted in a total of $91,000 in fines. Some of the remaining cases could result in even higher penalties.

John V. Currie