Inner Containers in UN Single Packaging?

When shipping dangerous goods, shippers often use either combination or single UN-rated packaging. Combination packaging is a type of packaging that was UN tested with one or more inner packaging secured in an outer packaging. Below is an example of inner plastic bottles in an outer 4G box.

On the other hand, a single packaging is a packaging other than a combination packaging that was tested without inner containers and can be shipped on its own. Below is an example of a single packaging, in this case, an open-head 5-gallon metal drum that is UN-tested on its own with liquids and no other internal packing components.

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Although single packaging, by definition, is tested without inner containers (such as plastic bottles, for example), a question I often get from clients is whether or not it would be compliant to add inner containers inside of a UN-rated single packaging.

Can you add Inner Containers to a UN Rated Single Packaging?

The short answer per PHMSA is yes. There are 2 PHMSA interpretations out there that address this question. For example, the interpretation below states that an authorized single packaging for dangerous goods may contain inner receptacles that are compatible with the lading as long as it doesn’t affect the performance of the specification packaging. The single packaging may remain marked as a single packaging and need not be retested. As long as the completed package meets the general packaging requirements of Part 173, Subpart B (see 173.21(e) and 173.24), this would be compliant.

Similarly, this interpretation says that the steel drum in question that is an authorized single UN packaging, may contain inner receptacles that are compatible with the lading as long as the inner receptacles would not adversely impact the level of performance of the packaging and that the packaging would still remain marked as a single packaging.

Keep in mind that the closing instructions of the single packaging must still be closely followed, and you must still acknowledge the details of the UN specification marking that is associated with the single packaging, such as the rating (X, Y, or Z), total gross mass for solids, and the specific gravity for the liquids. In addition, be sure to review the appropriate regulations and packing instructions for whatever product you are looking to ship to determine if the UN packaging you are using is compliant.

Here at ICC, we offer a wide array of both UN-rated combination and single packaging for your dangerous goods needs.

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.