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SUPPLYING UN CERTIFIABLE BOXES






SUPPLYING U.N.CERTIFIABLE BOXES


PRESENTED TO

AICC CONFERENCE
APRIL 23, 1993

(REVISED MAY 14, 2004
TO REFLECT UPDATED REGULATIONS)


PREPARED BY

CHARLES E. TUDOR, CP-P/MH
PACKAGING CONSULTANT
3869 MAMMOTH CAVE COURT
PLEASANTON, CA 94588


PRESENTED BY


WESTPAK, INC.
83 Great Oaks Blvd., San Jose, CA 95119
(408) 224-1300 FAX (408) 224-5113
www.westpak.com
________________________________________________







SUPPLYING UN CERTIFIABLE BOXES




Presented to AICC Conference
April 23, 1993


(Revised May 14, 2004 to reflect updated regulations)
























Charles E. Tudor, CP-P/MH
Packaging Consultant
3869 Mammoth Cave Court
Pleasanton, CA 94588
925-462-4493
FAX: 925-462-8396
cetudor@ix.netcom.com CERTIFIED OR CERTIFIABLETHAT IS THE QUESTION

With the issuance of the Docket 181 final rule in October, 1991, the requirements for hazardous
material packaging have changed dramatically. These wide sweeping changes were driven by
the need for improved reliability and internationally recognizable emergency response
information. It was the need for improved package reliability and standardization that is
responsible for the switch to performance oriented packagingPOP design.

This new philosophy requires that all packages be tested as complete systems in the manner of
their intended use. In other words, if a single box design is to be used to ship a variety of inner
packagings or articles, it must be tested (and certified) in each packed configuration. Each
configuration is referred to as a design type.

BASIC BOX MAKING RULES

The rules for making a box, from the box makers point of view, have gotten simpler in terms of
detailed material and process specifications. But the general rules have become more definitive
with more emphasis on shipper responsibility. Yet, many box makers have failed to recognize
the key elements of simplicity (or should I say complexity) in the new system.

The specification for a 4G Fibreboard box is only four short paragraphs long. Compare this to an
old DOT-12B or 12A box specification which is considerably longer.

The 12A, for instance, was limited to two grades of singlewall fibreboard.. 4G has no limits on
the grade of board. 12A requires both liners to be water resistant. 4G requires only one to be
water resistant. 12A requires a glued manufacturers joint to be glued throughout the area of the
lap. 4G does not specify so long as it performs.

About the only new requirement imposed on a 4G box is the test for water resistance of the outer
liner (Thirty minute Cobb moisture absorption test in accordance with ISO 535). Although the
old DOT spec boxes had to have water resistant liners, no test was called for to establish good
from bad.

See the appendix for the complete 4G specification as presented in 49 CFR Code of Federal
Regulations.

SO WHEREIN LIES THE DIFFICULTY?

The difficulty starts when your customer asks for a UN CERTIFIED box as opposed to a UN
certifiable box. Under the rules you simply cannot supply an empty box with a UN mark on it
(analogous to a BMC). Your box must participate in a performance test after having been
packed with somethingand pass. The mark then represents certification of a complete
package or packaging system. Now this was true of the old DOT-12A, but the more
commonly used DOT-12B had no specific testing called for in 49CFR.

In the normal scheme of things, it is the shipper who should be testing the box. It is the shipper
who should be specifying all the detailed requirements for the box. Only the shipper knows what

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will be shipped in the box and what the transportation environment is. The smart shipper knows
what he needs to be in compliance with the regulations. The smart shipper will ask you to
provide certifiable test specimens and will provide you with the certification mark to be printed
on production boxes when he places the order. The not-so-smart shipper will ask you to design
the box for him. The not-so-smart shipper will ask you to also certify it for him. You know, the
old turn key design approach because he cant be bothered. The not-so-smart shipper thinks he
can skip the development phase and jump right into the qualification (certification) phase.

Lets face it. It is almost impossible for you to ensure complete compliance for a customer who
does not know for sure what he needs. If he doesnt know, how can you possibly know. For
instance, there may be requirements for design features that will affect fit predicated on the
products being shipped or the mode of transportation that you have no knowledge of. So, it is
one thing to assist the customer in doing his job and quite another to assume responsibility for
his job as a hazmat shipper.

KNOWLEDGE, EXPERIENCE AND QUALITY CONTROL

In the real world the box maker rarely receives a complete specification. So how does he protect
himself? With knowledge, experience and quality control. (Indeed DOT requires employees of
manufacturers of hazmat packaging to be trained in the regulations. Training requirements are
found in paragraph 172.700 and included general awareness as well as function specific
training.)

When you are asked to supply certification samples, how you go about it is key to your success.

First
Make certain the box complies with those four little paragraphs in the 4G
specificationparticularly the moisture resistance requirement and the
quality of the manufacturers joint. (Cobb testing will be checked by 3
rd

party Certifiers, and some manufactures are inclined to use a different
adhesive on prototype box joints).

Second
Make sure all samples are uniform. They should be production if possible.
If they come from the sample room, it is your responsibility to ensure that
they are equivalent to production boxes. (i.e. same board (same liner mfg
if possible), same size, same joint etc. It is your responsibility to ensure
that they are the same as production boxes.

Third
Make certain the quality of sample boxes are no better than you are
willing to supply 100% of the time for production. This is the best way to
protect yourself from noncompliance exposure. Once the test boxes are
certified, they automatically set the standard for all production box
materials and workmanship that follow. DOT expects every production
box to be capable of passing the certification test protocol as it was
applied to the test articles.



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(Here comes the experience)

You should know and document the source, make up, % recycle, density, Cobb, ECT value, tear
strength, Mullin and any other trait of the board used in the test boxes as well as production
boxes. The more documentation the better. The materials in a production box should be
traceable to their source through a production coding system.

If any physical characteristic should change that would cause an already marginal design type to
fail, you may be caught holding the bag (a recall of a large production order). Of course, you
may be forced to change liner board or even liner board suppliers during the course of
production. This can be a significant change. Your best bet is to retest (or recommend your
customer retest) when this happens. Indeed, DOT expects you to have a suitable QC program in
place to ensure reliability of all production hazmat boxes.

Ask for the certification test report from the shipper, It can be very valuable to have the test
report on the package design type so you can determine for yourself whether the design is
conservative or marginal with respect to your boxes. Your QC program may not need to be as
critical if the design is conservative. The test report sets the standard in determining if you or the
shipper violates the design type rules of equivalency that mandates retesting, or any other
attribute of the package that may cause it to fail periodic retesting.

THE TEST PROTOCOL

By all means be familiar with the test protocol for 4G fibreboard boxes. Any production
verification testing you perform should be based on the protocol applicable to the design type.

There are three primary tests for 4G boxes design types: Drop, Stack, and Vibration.
Environmental conditioning is require for official qualification. The required drop h