PHMSA Issues Notice of Enforcement Discretion on Packaging Tape

If you ship UN boxes, you know the importance of using the correct tape called out by the closing instructions. As a matter of fact, I have written several blogs myself on the topic.

There have been some interpretations out there that PHMSA has put out previously that allow dangerous goods shippers to add more strips of tape to your UN box as long as you use the same one it was tested with or even a wider version of the same tape, but historically there weren’t any circumstances where you are allowed to use a different tape, until now. 

The Pipeline and Hazardous Materials Safety Administration (PHMSA) has issued a Notice of Enforcement Discretion in regard to packaging tape on UN boxes. Due to supply chain challenges making it difficult for many companies and industries to obtain required materials to perform daily functions, certain tapes that are used during the testing of UN specification packaging may be difficult to obtain over the next several months. For this reason, PHMSA is temporarily allowing the use of tape that was not specifically used during the testing of UN specification packaging. There are some conditions to this below: 

  1. It must be the same material as the tape in the original packaging test report. 
  2. The tape must be capable of demonstrating no diminished capabilities in yield strength, thickness, ductility, width, length, or adhesive properties 
  3. It must be compatible with the packaging. 

All other characteristics of the packaging materials must be the same as what was used for the originally tested packaging, such as inner packaging, outer packaging basis weight, etc. This notice of enforcement discretion is effective through August 31, 2022. For more details,  click here to see the official Notice of Enforcement from PHMSA. You can also visit their website for more information. 

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Michael Zendano

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.

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