(Is it really possible to reuse a 4G packaging material?)

Q.
The regulation states that plastic drums, plastic jerricans and flexible IBCs have a permissible life time of 5 years from the date of manufacture. Is it really true that if a 4G box is just as new it can be used without any time limit?  (31 Jul 12)

A.
IATA DGR 5.0.1.4 ”Package/Overpack Re-use”quotes: “The shipper must ensure that before a packaging authorized for re-use, or an overpack is re-used, all inappropriate dangerous goods Mar ings and labels are removed or completely obliterated.” Further, in its Note, it says: “Not all packages are intended to be re-used for shipments of dangerous goods. When a package meets the conditions of 5.0.2.5 and May be re-used the shipper must have access to the information required in 6.0.1.4.”

DGR 5.0.2.5 referred to in the above clause reads: “New, manufactured, re-used or reconditioned packagings, which are listed in Table 5.0.C. must meet the applicable requirements of Section 6 of these Regulations. Such packagings must be manufactured and tested under a quality assurance programme, which satisfies the appropriate national authority, in order to ensure that such packagings meet those applicable requirements. Where packagings are required to be tested in accordance with Subsection 6.3, their subsequent use must be as specified in the applicable test report and conform in all respects with the design type which was tested, including the method of packing and size and type of any inner packagings, except as provided for in 5.0.2.1.2 and 6.3.1.2. Before being filled and handed over for transport, every packaging must be inspected to ensure that it is free from corrosion, contamination or other damage. Any packaging which shows signs of reduced strength as compared with the approved design type must no longer be used or must be so reconditioned that it is able to withstand the design type tests. For definitions of remanufactured packages and reconditioned packages as used in these Regulations, see Appendix A.”

Furthermore. DGR 6.0.2.4 also referred to in the clause reads: “Manufacturers and subsequent distributors of packagings must provide information regarding procedures to be followed (including closure instructions for inner packagings and receptacles), a description of the type and dimensions of closures (including required gaskets) and any other components needed to ensure that packages as presented for transport are capable of passing the applicable performance tests of Subsection 6.3 to 6.5 and the pressure differential requirements of 5.0.2.9, as applicable.”

Judging from the aforementioned requirements, before a 4G packaging is re-used, the 4G need to undergo a performance test to ensure that the 4G is up to standards. Packaging material such as cushioning material, absorbent material, sealing tape, etc, similar to those which had been originally used must be assembled. To do this, it is necessary to get hold of the box manufacturer’s original assembly instruction papers. Such instruction papers would probably be in the hands of the original shipper and would almost be impossible for the party who wish to re-use the 4G to have access to. Particularly for 4G, there would be a need to test to check for water absorption during its first use. Considering all these factors, it would be almost impossible to prove that a previously used 4G is up to standards and therefore would be impractical to be re-used.


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