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PHMSA Seeking Comments on UN Package Testing

PHMSA Seeking Comments on UN Package Testing

As mentioned in my previous blog, there are many requirements when it comes to UN testing a 4G combination box. Per the 178.601 (e) in the 49CFR, periodic re-testing of UN rated combination packaging must be conducted every 24 months. This means that in order to keep producing your UN rated packaging once the test report has expired, you have to have a new valid test report for that particular design. This 24-month requirement is once again becoming a hot topic among packaging professionals. Is this too short of a time period? Is it too long of a time period? Or is it just right? These questions were first brought up back in 2017 and are now being discussed again as PHMSA is looking for comments from the public.

UN Testing Interval Up for Comment

UN testing is intended to demonstrate whether or not a manufacturer’s packaging continues to meet the standards required for the safe transportation of dangerous goods. Several comments related to the periodic retest requirement for UN specification non-bulk combination packaging and IBCs were submitted to the 2017 Regulatory Reform Notice docket. These comments came from The Reusable Industrial Packaging Association (RIPA), the Industrial Packaging Alliance of North America (IPANA), and the Sporting Arms and Ammunition Manufacturers Institute (SAAMI). The comments requested that PHMSA extend the periodic retesting interval for up to 5 years for UN specification non-bulk packaging and IBCs to align with international standards that permit a longer retest interval. This would be a big jump from the current 24-month requirement. PHMSA is now officially requesting comments from the public on the following questions to evaluate RIPA, IPANA, and SAAMI’s requests among others:

  1. Can a package manufacturer or a UN Third-Party Packaging Certification Agency demonstrate through data, modeling, or other means, that a packaging design that is tested every 60 months performs as well as a design tested every 12 to 24 months? Explain.
  2. How have manufacturers’ quality assurance procedures evolved and improved since the implementation of UN POP system? Please provide specific examples for all packaging types believed to warrant a longer design qualification interval.

The Comments pertaining to these questions and others must be received by October 3, 2023. However, PHMSA will consider late-filed comments to the extent possible.  For access to all of the questions up for comment as well as instructions on how to provide the comments to PHMSA, the full notice of the proposed rulemaking is located at the link below.

Do you have questions about UN Packaging? Take a look at our UN Packaging FAQ or contact our team of experts at 855.734.5469 or send us an email, we’re happy to help.


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Michael Zendano

Michael Zendano started with ICC Compliance Center back in 2016 with several years in the packaging field as a Quality Control Manager. In addition, he has 8 years experience in teaching. Michael works at the Niagara Falls Office as the Regulatory Packaging Expert where he manages packaging projects and procedures and is a member of the Institute of Packaging Professionals (IOPP) and The Chemical Packaging Committee (CPC) . Degrees: M.S. Science of Education.