PHMSA Update: Tape Specifications vs Packing Instructions

PHMSA Changes Mind on Tape

If you are a frequent shipper of dangerous goods, then surely you know the importance of the type of tape that you use to close your hazmat packaging. In fact, a while back I wrote a blog on this very topic.

It doesn’t take much to fall out of compliance of the regulations outlined in the 49 CFR 178.601 (4) (ii) when it comes to tape. It’s quite simple, you either use the type of tape the package was tested with and is outlined in the closing instructions, or it is considered non-compliant.

Per the interpretation below, PHMSA even went as far as saying that using a wider version of the same exact type of tape was not permitted when using a UN tested outer box, stating specifically that, “it does not conclusively demonstrate how the package will perform when tested or transported.” Meaning if the box was tested with a type of tape that is 2 inches wide, you couldn’t use a 3-inch wide version of the same exact type.

Read the original interpretation.

However, recently PHMSA seemed to have a change of heart on this topic.

What’s The Change?

Recently PHMSA has decided to rescind the above interpretation, stating that, “increasing the width of the tape from that specified in the packaging test report and closure notification does not constitute a change in design, provided the tape is otherwise of the same specification originally tested” per the clarification below.

Read PHMSA’s response.

This means that moving forward, if you decide to use the exact same type of tape (tensile strength and other types of relevant properties in industry tested standards etc.), but choose a wider version, it is now acceptable according to PHMSA. This is good news, as it slightly loosens the regulations a bit. However, still remember to always verify on the closure instructions the type of tape that is required per the test report. You should never assume that it is okay to substitute a stronger tape for a weaker one, or a kraft tape to a clear tape.

Generally speaking, using a different tape on the outside of a package is no different then changing inner components within the package, it is considered a design change and is non-compliant. If you have any questions regarding our tape and packaging feel free to contact ICC Compliance Center at 888-442-9628 in the USA, 888-977-4834 in Canada.