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Am I Using the Right Tape on my HazMat Shipment? (FAQ)

By March 12, 2018September 12th, 201949 CFR, PHMSA

Man preparing shipment

Frequently Asked Questions About Tape Being Used With UN Boxes

Often times I get questions regarding which type of tape could be used with the various packaging we sell here at ICC Compliance Center. Like many other answers to questions, most of the questions can be answered straight from the regulations. As many of us know, sometimes when it comes to packaging, the regulations may not be specific enough to the questions we have. That’s when I turn to the PHMSA Interpretations for guidance.

What are PHMSA Interpretations?

PHMSA interpretations are written explanations of the hazardous materials regulations by various members of the D.O.T. They come in in the form of letters that are answering specific questions asked by a wide variety of dangerous goods professionals. They are to be used only as a form of guidance when following the regulations.

Do keep in mind that the interpretations that are currently posted in the database reflect the current application of the 49 CFR to the specific questions and may be removed if there are changes to the regulations or deemed inaccurate. The PHMSA interpretation browser can be found on PHMSA’s website.

HazMat Shipment Tape FAQs

Q. Can I put more strips of the tape than what is referenced in the closing instructions along the seam of the box?
A. Yes. Per Interpretation Response #06-0129 at the link below, as long as the specified tape in the closing instructions is used, the application of additional tape on the box is allowed and would not require the box to be retested with the conditions in mind
Q. Our box was specifically tested with 3M 305 Tape per the closing instructions. Is it okay to use a different tape that is stronger and wider tape than the tape referenced in the closing instructions?
A. No, Per the 49 CFR 178.601 (4) (ii) and the above interpretation response, the structural design of the tested outer packaging (i.e., methods of construction, materials of construction, strength characteristics of materials of construction, method of closure and material thicknesses) has to be maintained in order to remain compliant. In this case a change in tape, even if it is stronger is not permitted

Information provided by using interpretation #06-0129:

The key with taping a UN box is to make sure you always reference the packaging instructions to ensure you  are using the correct tape with the right amount extending over the edge of the box.  Never assume the tape you have in stock is the correct tape that keeps your UN Package in compliance. If a question regarding our packaging arises, feel free to contact me at 1-888-442-9628.

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.