Can I Make changes to my 4G Combination Package?
Some time ago, I wrote a blog that outlined the benefits and regulations of the 4GV packaging. Often referred to as Variation 2 packaging, we discussed the main benefit of this packaging is that different types of inner containers can be used whether they are liquid in glass bottles, metal cans, plastic bottles, or different types of solids. But what about non-4GV packaging (basically any combination package that has a UN marking on it that excludes the “V”)?
Can changes be made to the inner packaging? Here are some questions below that will clear up some of the confusion.
Replacing Plastic with Metal
PK-1GRPC 4G Plastic Container Combination Package
UN Marking: 4G/Y5.1/S
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- Q. So what we have here is our PK-1GRPC kit. This includes a plastic HDPE bottle and a corrugated box. Can this box also be used to ship dangerous goods with a tin plated paint cans?
- A. No. This box was tested at the lab with a one gallon HDPE bottle, so in this case you would not be allowed to use this box with any other type of inner container with a different structural design. 178.601 (g) (1) (i) (a) TP14850 8.1.2.3 (a)
Substituting an Insert for Absorbent or Adding Additional Cushioning
PK-NQTCA 4G Paint Can Shipper
UN Marking: 4G/Y4.0/S
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- Q. This kit is our PK-NQTCA shipper. It was tested in the lab with quart size paint cans, a corrugated insert, and a ringlok. Can I remove the corrugated insert and fill the box with packing peanuts in its place when shipping dangerous goods in the quart can?
- A. No. Because this was tested in the lab using the corrugated insert you are not permitted to remove it per 178.601 (g) (1) (i) (e) . TP14850 8.1.2.3 (d)
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- Q. For the same example, would I be allowed to use the corrugated insert with the quart can/ringlock, but also add packing peanuts to the inside for extra cushioning?
- A. Yes. Packing peanuts can be added to the corrugated insert and ringlock combination as additional cushioning material provided it provides at least an equivalent level of performance. 178.601 (g) (4) (v). TP14850 8.1.2.2
Quart Cans with Different Dimensions
PK-NQTFCA 4G Combination Packaging Foam Shipper
UN Marking: 4G/X2.2/S
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- Q. The above is our PK-NQTFCA foam quart can shipper. I have a similar quart can than was used during the D.O.T testing, the only difference is it is a ½” shorter. Can I still use this box to ship my dangerous goods in my quart can?
- A. Yes. Per 178.601 (g) (4) (III) and TP14850 8.1.2.3, you are allowed to ship an inner container with the same design type (quart round can) as long as it is equal to or smaller in size and mass. Although if there is a significant difference, excess void space should be taken up with additional cushioning to prevent moving of inner packaging during transportation per Per 178.601 (g) (4) (V), TP14850 8.1.2.1 (a).
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Smaller Closure Type
PK-MTM11 4G Combination Metal Can Shipper
UN Marking: 4G/X9.6/S
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- Q. The above kit is the PK-MTM11 Jet fuel shipper. This included a Corrugated box, Red gallon steel can and an antistatic bag. This kit was tested in the lab with a red gallon steel can with a 2″ closure. I have the same exact steel can/closure design, but the only difference is the closure on top is ¾”, can I use my can with this box?
- A. Yes. Per 178.601 (g) (1) (i) (c), inner packagings can have the same or smaller openings if the closure is of similar design (e.g., screw cap, friction lid, etc.). In this case the closure is smaller, so it is permitted. 8.1.2.3 (c)
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