It’s every industrial company’s worst nightmare. A package containing hazardous materials isn’t packaged securely, or it’s labeled incorrectly and is mishandled. The package is breached and the hazardous material leaks into a warehouse or distribution facility. In the best case scenario, the company faces a fine and inspections. In the worst case, a worker is injured or even killed.
If you’re new to the world of hazardous materials, you’re about to enter a complicated area of risk and regulation. The rules regarding hazardous materials may seem overwhelming at first, especially if you’re trying to do the packaging and shipment in-house.
You could be subject to a maze of regulations from agencies like the Department of Transportation, the Environmental Protection Agency, and OSHA. Additionally, each state usually has its own set of hazardous material requirements.
It’s always wise to work with an industrial packager who is experienced with hazardous materials. They can tap into their knowledge to ensure your materials are packaged safely and your team members are protected. They can also take the liability off your plate and ensure that you are compliant with all relevant regulations.
When choosing a hazardous material packaging partner, it’s important that you speak the language so you can ask informed questions. Below is a list of some of the most important factors to consider when planning your hazardous materials packaging process. Whether you’re packaging in-house or outsourcing, it’s critical that you understand these components and how they fit into your process.
The packaging process for hazardous materials always begins with classification. The classification system is administered by the U.S. Department of Transportation. Its purpose is to provide a universal framework to easily identify what materials may be within a container and what hazards they may present. The DoT offers a helpful chart as an overview of the classification system.
The nine universal classifications for hazardous materials are:
- Class 1 - Explosives
- Class 2 - Gases
- Class 3 - Flammable Liquid and Combustible Liquid
- Class 4 - Flammable Solid, Spontaneously Combustible, and Dangerous When Wet
- Class 5 - Oxidizer and Organic Peroxide
- Class 6 - Poison and Poison Inhalation Hazard
- Class 7 - Radioactive
- Class 8 - Corrosive
- Class 9 - Miscellaneous
The classification should inform the risks that exist as well as the type of packaging required. It will also tell you the classification labeling needed on the outside of the container.
Finally, be aware that not every company that packages hazardous materials is able to handle every type of material. For example, at Deufol, we only package classes 2, 3, 6, 8, and 9. Make sure your packaging company has significant experience in the relevant classification before partnering with them.
Once you know your material’s classification, you can begin to think about packaging and how it should be designed to minimize risks. Of course, to do that, you have to be able to identify all possible risks.
Many industrial companies are highly skilled at designing and manufacturing their own products. But they’re not experienced packagers, especially when it comes to hazardous materials. They may not have the depth of knowledge necessary to imagine every possible outcome or to accurately gauge the probability of certain risks.
There are any number of errors or miscues in the package design that could lead to real danger. The package may not be stable enough and could crack in transit. The crate may not have sufficient cushioning or absorbent materials to mitigate shock and volatility. The materials may be temperature sensitive, and the package may not have been cooled or heated to the right temperature before the materials were loaded.
Even the smallest engineering discrepancies or production errors can make a package too risky to use for hazardous materials. An experienced hazardous material packager can identify these risks and engineer a packaging process that protects your product, your team members, and anyone else who handles the package.
Labeling and Marking
That DoT classification guide suggests that the labeling process for hazardous materials is fairly straightforward. You simply use the diamond-shaped symbol that aligns with your material’s classification, right?
That’s only half the battle. The label refers to the actual diamond sticker that goes on the outside of the crate. There are also markings, and those markings can vary based on a wide range of factors and regulations.
For example, the UN has a four-digit coding system to identify the specific material within the package. That number will likely need to be marked clearly on the label.
You also may notice that each classification has sub-classes. For instance, class 2 is for gases. However, if it is a poisonous gas, that falls under class 2.3. That needs to be displayed on a placard on the container.
There could also be “This End Up” markings required if the material must stay in a certain position throughout the transit process. You may have additional markings depending on whether the container is considered bulk or non-bulk. Hazardous waste has its own set of markings. Certain states have their own required markings for certain materials and weight classes.
Understanding the maze of labeling and marking regulation is akin to being fluent in a foreign language. Very often, industrial companies try to package in-house and then realize that learning these rules and guidelines is almost a full-time activity.
Again, this is where a packager who handles hazardous materials can help. They know what labels and markings need to go on your package because they do that work everyday. Rely on their knowledge to keep you in the clear so you can focus on what you do best.
The Department of Transportation doesn’t just offer guidance on classification and regulations about labeling. They also mandate that all hazmat workers receive a substantial amount of training.
Who is considered a “hazmat worker”? The DoT describes a hazmat worker as anyone who directly affects hazardous materials transportation safety. That includes everyone from the person who chooses the classification, the person who adheres the label to the crate, the engineer who designs the package, the facility security guard, and even the worker in the distribution department who wheels the crate onto the truck.
Basically, anyone who has anything to do with packaging and shipping has to meet DoT training requirements. There are different types of training required depending on function. Everyone has to participate in the most basic level, General Awareness Training. Other types of training include:
- Function-specific Training
- Safety Training
- Security Awareness Training
- Security Plan Training
- Driver Training
Workers must receive this training before they start working with hazardous materials. They also must spend a certain number of hours working with hazardous materials under direct supervision. Finally, all workers have to update and continue their training at least once every three years.
Training is costly. If you’re already working with a limited staff, it’s a drain on precious time and resources. You can hire a training company to help you and your team meet the requirements. Or you can save yourself the trouble and work with a hazardous material packager who has their own staff who is already compliant with training standards.
Every step discussed thus far is meant to prevent an accident from happening. The labels and markings generate awareness and communicate how the package should be handled at each step. Package and crate design minimizes risk and ensures safety. Training boosts handler knowledge and promotes safety.
Even with all of these actions, though, accidents can and do happen. When they do, it’s important to have a risk management plan in place. Your risk management plan should address the following questions and more:
- What are all of the possible negative outcomes if the material breaches the package?
- What immediate steps should team members take to protect themselves and limit damage?
- Who should be notified?
- What audit steps can you take to ensure risks are being appropriately managed?
Again, developing a risk management plan is a big undertaking. It requires a unique set of knowledge and experience. When interviewing potential packaging partners, ask to see a sample risk management plan. That should show you how prepared they are to not only prevent accidents, but also limit damage should an accident occur.
Hazardous materials are a necessary risk in many industries. However, that doesn’t mean they have to pose an outsized risk to your company or your workers. Partner with an experienced packager who can take the risk off your plate and ensure product quality and worker safety.