TRUST ME?
Whenever you decide to go over a 49 CFR Department of Transportation(DOT), Pipeline and Hazardous Material Safety Administration(PHMSA), United Nations(UN), specification hazardous material or waste container with shrink wrap or straps to protect, secure and consolidate, you have now prepared an overpack, so make sure you hold up your end of the bargain.
Most people don’t see the overpack exception, as an exception. DOT never requires shippers to overpack authorized containers, ever. It’s a favor that you’re asking of the carrier or transporter and the DOT inspectors. You’re asking them for trust.
When two containers are required, both inner and outer, it's a combination packaging, not an overpack. Package markings are visible on combination containers as the outside container is required to bear the manufacture marks in 178.502 and 178.503.
If you place eight combination boxes containing bottles of Acetone onto a wooden pallet, in most cases, you would strap or shrink wrap the boxes onto the pallet to protect and prevent the boxes from sliding off the pallet during transportation.
Strapping or banding eight combination packagings onto a pallet is definitely an overpack as the straps would go over the UN/DOT boxes. Although I doubt those two inch wide straps or bands would obscure the proper shipping name, Acetone, the UN1090, the Class 3 Flammable Liquid label or the manufacture marks ( ie; 4G/Y145/S/83/USA/RA ) on every box, at this point, I believe the above overpack would meet all of the requirements in 173.25 by doing absolutely nothing further to the packaging.
Unfortunately, if you were to heavily shrink wrap or band pieces of cardboard around those boxes onto a pallet and you could not see the UN/DOT manufacture specification container marks on the UN 4G fiberboard boxes, as it was covered or obscured, the shipper and generator would now be required to put all of Part 172 Hazard Communication 172.300 marks and 172.400 labels on the shrink wrap in addition to the OVERPACK mark. This would certify that the containers with the obscured manufacture marks were authorized under the Subchapter C Hazardous Material Regulations(HMR).
A third type of overpack would be to put four combination containers of acetone into a non-DOT/UN specification cardboard box, for convenience and protection from damage during shipment.
The proper shipping name, Acetone, the UN number, UN1090, the Class 3 Flammable Liquid label and the OVERPACK mark in 173.25, would be required on the non-DOT/UN specification cardboard box. That would assure that the shipper was using the correct DOT/UN containers.
Asking someone to trust you by putting the overpack mark on the container is a favor. It’s an exception, if I were a carrier, I’m not sure if I could trust all of my shippers or generators in every single case. Just because the packaging displays the OVERPACK mark, if you can’t see container marks, how do you know they’re the proper containers?
You’re not only asking the carriers and inspectors to trust that you’re using UN specification containers, in addition you’re asking them to trust that you know how to pick the proper ones.
That’s a lot of trust.
Don’t hesitate. Always appreciate your input, reach out if you have any questions or concerns. For example, I was corrected for using “packaging groups” as opposed to “packing groups” in a recent blog. These words really do matter, thank you.
I can always trust you to keep me honest.
Robert J Keegan
Publisher and President
Hazardous Materials Publishing Company
Transportation Skills Programs Inc
610-587-3978
Hazmat.tsp@gmail.com