The US Postal Service is taking a positive step to improve the safety of liquid packaging shipments. This step is significant, as the industry will begin to incorporate some components of UN 4GV combination packaging requirements among a wide variety of changes soon to be implemented. Here at ICC, we help you understand what these changes are and provide the solutions that ensure you meet these new stringent requirements.
Why Change?
The Postal Service has observed that a significant percentage of liquid spills results from mailers misinterpreting the existing packaging requirements for liquids, thinking their non-metal containers are not breakable. However, non-metal containers (i.e., plastic, glass, earthenware, etc.) are often the source of liquid spills in Postal Service networks. As a result, on July 9th of 2018, the US Postal Service proposed a new rulemaking on standards for mail pieces containing liquids. There was a comment period requesting public feedback on the proposed rules until September 18, 2018.
The proposed rule addressed two components:
- Clarification of existing language that specified packaging and markings for mail pieces that contain liquids in containers greater than 4 fluid ounces; and
- Extending the triple-packaging requirement for breakable primary containers with 4 ounces or less.
What are the Changes and the Compliance Solutions?
Effective on March 28, 2019, the adopted changes published in the final rule include:
- Labeled Boxes: Mailers must mark the outer container of a mailpiece containing liquid to indicate the nature of the contents (i.e., liquid), and include orientation arrows in accordance with Publication 52, section 226. Our orientation labels are fully compliant with the above publication and can be placed on the side panels of any box containing liquids whether it is UN regulated or not. https://www.thecompliancecenter.com/ca/product-category/labels/shipping-and-handling/
- Bottles and Cans: Must now use screw-on caps with a minimum of one and one-half turns, soldering, clips, or similar means to close primary containers containing liquids. We offer many inner packaging options designed to ship liquids and have a wide variety of caps and closures as accessories.
https://www.thecompliancecenter.com/ca/product-category/packaging/bottles-cans/
- Pails and Drums: Liquids in steel pails and drums must have positive closures, such as locking rings or recessed spouts under screw-cap closures and may be mailed without additional packaging. If hazardous substances are being shipped, be sure that you use UN rated single packaging. We have plenty of options including closed head and open head plastic and metal drums at the links below:
https://www.thecompliancecenter.com/ca/product-category/packaging/steel-single-packaging/
https://www.thecompliancecenter.com/ca/product-category/packaging/hdpe-single-packaging/
- Breakable Containers: Breakable containers including, but not limited to, those made of glass, plastic, porcelain, earthenware, and metal containers with pull-tabs (pop- tops), or friction-top closures, having a capacity of more than 4 fluid ounces, must be triple-packaged according to the following requirements. This is where the similarities of the 4GV requirements come into play per the 49 CFR 178.601(g)(2)(v) and (vi) as well as TP14850 12.7 b and c:
- Cushion the primary container(s) with absorbent material capable of absorbing all of the liquid in the container(s) in case of breakage; there are a variety of absorbents we can provide you at the link below:
https://www.thecompliancecenter.com/ca/product-category/packaging/absorbents-and-cushions/ - Place the primary container inside another sealed, leak-proof container (secondary container), such as a watertight can or plastic bag; and use a strong and securely sealed outer mailing container durable enough to protect the contents and withstand normal processing in Postal Service networks. Below is a link to our various leak-proof bag sizes that would fulfill this requirement. https://www.thecompliancecenter.com/ca/product-category/packaging/packaging-accessories/ Note: As an alternative, mailers may use containers certified under the International Safe Transit Association (ISTA) Test Procedure 3A. Mailers must, upon request, provide written test results
- Cushion the primary container(s) with absorbent material capable of absorbing all of the liquid in the container(s) in case of breakage; there are a variety of absorbents we can provide you at the link below:
In regards to extending the requirement to triple-package breakable primary containers with a volume of 4 ounces or less, the Postal Service will not move forward with this proposal at this time. The Postal Service will continue to monitor the frequency and impact of spills originating for these smaller containers and make a determination at a future date regarding mailing standards revisions relating to smaller containers of liquids. For the full revision, please visit the link below:
https://www.govinfo.gov/content/pkg/FR-2019-03-18/pdf/2019-04894.pdf
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