FAA Puts Packaging To The Test

Q. What is DOT going to do about packaging of hazmat for air shipments?
A. This topic was the subject of a lot of preparatory work and an all-day session of stakeholders in Washington in June. The issue is the perception of an increasing problem with leaking hazmat packages.

No doubt part of the perception relates to changing reporting practices rather than numbers of incidents, and varying practices among the carriers who file Form 5800.1 incident reports.

Another part of this perception comes from research conducted by the Federal Aviation Administration (FAA) through Michigan State, which shows an alarmingly high percentage of leakers in testing laboratories under what the FAA and air carriers describe as normal conditions of pressure, temperature, package orientation, and vibration.

It became clear at this meeting that identifying the normal conditions of air transport also has to include effective consideration of ground transport (and different vibration frequencies) to and from air facilities, and relatively rough handling at those sites and at intermediate sort facilities. A package handled separately as a parcel sees much more abuse than one handled as part of a unitized load. Packages processed by hand fare worse than those handled by automated equipment.

The International Civil Aviation Organization (ICAO) adopts air rules, the International Air Transport Association (IATA) publishes those rules, and national agencies such as the FAA have their own regulations. All expect hazmat packages to be able to withstand pressure and temperature differentials while being vibrated. During this meeting, however, it became clear that the rules on how to demonstrate this capability are not clear. Those who test at least prototype packaging designs claim to find and to resolve their problems, but their conclusions are based on actual testing. Those who describe their packaging as being "capable" of withstanding the tests, but who have not actually tested, appear to be kidding themselves.

Whether these agencies will march toward more testing of a different and more rigorous sort, or will simply clarify the obligations of a shipper to document the capability of packaging to withstand air conditions, is not known at this time. Something will change, because the current perception of hazmat leaks, whether on passenger or all-cargo aircraft, is unacceptable.

Another issue raised during this meeting was the reality that many companies packing hazmat never intend to have their product travel by air. It is distributors or other re-shippers or customers who put the packages into air transportation. No one offered a ready solution to this problem. Packaging every material to withstand air transport would work, but would be astoundingly expensive for items that never will be air-shipped. Marking packages to be "air eligible" was tried before, but also did not work. Wrapping everything in "Depends" and a plastic bag might work, but does not seem practical either.

Closures received a great deal of attention, because those closures may not be designed for pressure/temperature-differential shipment, or they were not closed or secured properly by the filler, or were opened and re-closed improperly. Gaskets and seals relating to closures also were described with the reality that it is difficult to maintain torque or equivalent leak tightness over time.

Watch for a lot more attention to this issue as DOT, including the Pipeline & Hazardous Materials Safety Administration (PHMSA) and FAA, as well as international authorities like the UN and ICAO, try to fix air packaging without making the concept of air distribution so costly as to make it an impractical alternative. If you prepare hazmat for air transportation, or operate aircraft to carry these packages, plan to get involved in the debate.

Lawrence Bierlein is a partner with McCarthy, Sweeney & Harkaway, P.C. (www.mshpc.com), in Washington, D.C. His practice is devoted to issues involving transportation of hazardous materials. He can be reached at (202) 775-5560, [email protected]

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