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In my previous blog concerning the DOT audit, we looked at the common VIOLATIONS that the DOT auditors find. 

Now, let’s break two of the packaging ones down a bit further.

First, let’s talk combination packaging. You are shipping UN1263 Paint Related Material, Class 3, PG II. You decide we are going to ship it in quart cans, two per package. You call ICC who has the perfect package to meet your needs. The package comes with the cans, rings, insert, box, and the instructions for assembly. 

How did that package come to be? In short, ICC gathered all of the various components from various suppliers and provided everything to the 3rd party test lab. The lab, in turn, assembled the packages per ICC’s instructions and ran them through the series of UN performance tests as outlined in the 49CFR regulations Part 178.600. Once the tests were completed, without fail, a UN packaging code was assigned, and the packaging instructions were finalized. 

Your shipment arrives, and you are now ready to prepare your Paint Related Material for transport. FIRST, you must review the assembly instructions. If you do not follow them exactly, you will be in VIOLATION. 

You must use ALL that was provided. The box, insert, can, ring, and specifically, the tape that is mentioned – “3M # 375 48mm clear tape.” A different brand, size, or type of tape will result in a VIOLATION. 

Now, you have assembled the box with the correct brand, size, and type of tape, but did you apply it in the same manner – “seal center seam with one (1) strip of 3M #375,48mm clear tape. Extend tape beyond each edge by at least 2″.” If you did not, you will be in VIOLATION. 

The assembly instruction advised you to apply a ring to the paint can. If the instruction advised you to use a tool to apply it, make sure you do; otherwise, you guessed it, you will be in VIOLATION.

I think by now you get my point. Reading the assembly instructions or closure instructions and following them exactly as they are written is key. Review the instructions each time you place an order because the package must be re-tested every two years, and sometimes there are changes. 

If you do not receive an assembly instruction, contact the vendor immediately. You must keep the assembly instruction for 90-days from the time of shipment, per the 49 CFR regulations Part 173.22. Finally, ensure all of your employees packaging the material are instructed in the proper means to assemble the package and use the tool. This would be considered “function-specific” training. 

At any time you need help, please contact our Regulatory Experts. We are always happy to help.

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4G UN Combination Boxes
Round Can with Lid (Unlined) - 1 quart
Round Can with Lid (Unlined) – 1 quart

Ringlok and Overseals

Packaging Accessories
Karrie Ishmael, CDGP

Karrie Ishmael has been with ICC since 1988. She has contributed to ICC's growth in various capacities, including customer service, sales, and marketing. In her current role as ICC's Senior Regulatory Expert and SDS author, Karrie conducts hazardous materials training classes in 49 CFR, IATA, IMDG, TDG along with OSHA and WHMIS hazard communication courses. When not training, she writes safety data sheets for customers to comply with North American and European requirements. She actively participates in many associations, including DGAC, COSTHA and is the former chair of SCHC’s OSHA Alliance Committee.

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