What does one do when the need to ship something outside the realm of “ordinary” arises?
Last month I had to ship a couple small bottles of bromine for a client. It was more involved than I originally expected. Before even getting close to the bottle, I wanted to know what was so bad about it. Why is bromine hazardous?
I read through the MSDS to get an idea of what I was about to work with. This shipment was going by ocean so I also had a look at the IMDG code. According to IMDG, it has an extremely irritating odour, is a powerful oxidant, and is highly corrosive to most metals. Also, it is toxic if swallowed, by skin contact or by inhalation. Furthermore, it can cause burns to skin, eyes and mucous membranes. To say the least, it is pretty nasty stuff.
Here is the classification:
UN 1744, BROMINE, CLASS 8(6.1), PG I
As you can see, it is packing group I material. I went to IMDG packing instruction P804 to see what was required for packaging and found that it read completely different than the normal P001 and P002 that one frequently sees. This instruction lists four possible ways that this material can be packaged, all varying depending on what type of inner package is used to contain the actual liquid. To give you an idea, part 1 refers to using glass inners, part 2 refers to using metal or polyvinylidene fluoride (PVDF) inners, part 3 refers to using drums or composite packagings, and part 4 talks about using pressure receptacles. This long set of instructions actually became quite simple when I learned that the bromine was being shipped in 0.5 L glass bottles.
I definitely didn’t even want to consider transferring the material to something else for several reasons. First off, it is really nasty and would pose a threat to my body and those of anyone around me. Keeping it in the same bottle also avoids the headache of considering compatibility questions between the bromine and the inner means of containment that we would create by transferring it to a new inner package. The manufacturer has been packaging it in glass without incident so we’ll stick with that. In this case, this also ensured that the closures are sealed properly.
Here is what the section about glass bottles said:
Combination packagings with a maximum gross mass of 25 kg, consisting of one or more glass inner packaging(s) with a maximum capacity of 1.3 litres each and filled to no more than 90% of their capacity; the closure(s) of which shall be physically held in place by any means capable of preventing back-off or loosening by impact or vibration during transport, individually placed in:
* Metal or rigid plastics receptacles together with cushioning and absorbent materials sufficient to absorb the entire contents of the glass inner packaging(s), further packed in:
* 1A1, 1A2, 1B1, 1B2, 1N1, 1N2, 1H1, 1H2, 1D, 1G, 4A, 4B, 4N, 4C1, 4C2, 4D, 4F, 4G, or 4H2 outer packagings.
Lets break this down:
- I can use a 4G box as my outer packaging, so long as it does not exceed a gross weight of 25 kg. That’s easy enough.
- The maximum capacity of the inner bottles mustn’t exceed 1.3 litres. That is certainly peculiar to read, but luckily we’re working with 0.5 L bottles. There is no way they would ever hold 1.3 litres so we’re fine there.
- The bottle cannot be filled to more than 90% capacity. I’ve heard of ullage, but that’s an odd request.
- The caps have to be held in place with some tape. That’s already done. Actually the manufacturer gave them to me with tape already on them.
- We have to use some sort of metal receptacle to hold the glass bottle. Luckily we have paint cans that will do the trick. The 1 gallon paint cans were too small in height, but we had larger ones that worked nicely.
In order to ensure that the bottles were filled to not more than 90% capacity, I needed to contact the manufacturer. Within two days I had confirmation in writing that the bottles are not more than 90% full. After that it was smooth sailing and packaging as per usual. Each bottle was put into a bag, each bag in a paint can along with vermiculite, each paint can in another bag, and each of those got put into separate 4GV boxes, again using vermiculite. Packages were marked and labeled and a document was written.
One good thing to take out of this exercise is to not be overwhelmed, even when faced with a new set of instructions that seems very intricate.
If you are faced with a similar situation, I would suggest the following:
- Think about your specific situation and what is required for it. In this case, once I knew that we had glass bottles, 75% of the instructions became irrelevant.
- Read the details for what is relevant for you. Ensure that you satisfy each part. Ask yourself, “If I do everything according to the plan in my head, am I going to be compliant with everything in this instruction?”
- Take your time so that you stick to your plan without missing any steps and don’t be afraid to ask for help. Having a colleague double check your work is a great way to eliminate mistakes.
Know what you are working with before you start your work. Read the MSDS and think about what you would do if an accident happened. In my case, I explained the potential hazards to all colleagues who might pass through the area with the dangerous goods. During the two days when we were awaiting confirmation about the bottle capacity, we kept the bottles in our warehouse. Nobody moved the packages containing the bromine because we planned ahead of time to dedicate an area for it with no foot traffic.
We get out-of-the-ordinary requests all the time. These are what help us learn, while keeping us interested. If you decide to tackle a project, just ensure that you are in compliance with the relevant regulations.