Does Plastic Single Packaging Expire?

Do you have old unused UN rated single packaging in your warehouse and wonder if you are still allowed to use it? Depending on what type of UN packaging and which mode of transport, the answer may be no. If it is a combination packaging, such as a 4G box, you should be in the clear as mentioned in my previous blog. However, for plastic single packaging, it could be a different story. Depending on the specific regulation and mode of transport, if you have single plastic packaging that is more than 5 years old, you may have to use something else to ship your dangerous goods.

Transport Canada

As usual, for UN non-bulk packaging standards within Canada we should consult the TP14850 (for now). Section 12.2 (c) states that a person responsible for filling a container must verify that the container is within the prescribed period of use. Specifically, this section goes on to say that the maximum prescribed period of use for plastic drums and jerricans is 60 months past the manufacturing date. This means if you have UN plastic open head or closed head drums, including plastic jerricans that they must be used within the first 5 years of the date of manufacture when shipping dangerous goods within Canada. If the plastic single packaging is older than that, you will have to choose a different packaging for your dangerous goods.

IMDG Code

If you are shipping by sea, in this case make sure you visit the IMDG Code, specifically in 4.1.1.15. This section sys that for plastic drums and jerricans, rigid plastics IBCs and composite IBCs with plastic inner receptacles, the period of use permitted for the transport of dangerous substances is five years from the date of manufacturer of the receptacles, except where a shorter period of use is prescribed because of the nature of the substance to be transported, unless it is otherwise approved by a competent authority. Similarly to Transport Canada, this would limit your use of UN single plastic packaging to 5 years, so if you have a UN plastic drum in your warehouse that is older than that, you shouldn’t ship it by sea.

IATA

IATA has almost the exact wording as IMDG code does when it comes to using plastic single packaging at 5.0.2.15, where it says: For plastic drums and jerricans and rigid plastic IBC and composite IBC with plastic inner receptacles, unless otherwise approved by the appropriate national authority, the period of use permitted for the transport of dangerous goods must be not more than five years from the date of manufacture of the receptacles, except where a shorter period of use is prescribed because of the nature of the substance to be transported. Sound familiar? Well unfortunately that old UN plastic drum you may have can’t be shipped by air either.

49CFR

Believe it or not, the 49CFR does not restrict your use of non-bulk packaging in terms of the age and when it is manufactured. As a matter of fact there is a letter of interpretation below on this very topic which basically says PHMSA does not impose a similar limitation on the use (initial or continued) of a packaging based on its date of manufacture:

https://www.phmsa.dot.gov/regulations/title49/interp/17-0031

So, if you are shipping domestically within the United States, and you have an unused UN plastic drum that is over 5 years old, you are allowed to use it per this interpretation.

Do you have questions about UN Packaging? Take a look at our UN Packaging FAQ or contact our team of experts at 855.734.5469 or send us an email, we’re happy to help.