U.S. Code of Federal Regulations
Regulations most recently checked for updates: Mar 30, 2020
This part prescribes the manufacturing and testing specifications for packaging and containers used for the transportation of hazardous materials in commerce.
(a) Applicability. (1) The requirements of this part apply to packagings manufactured -
(i) To a DOT specification, regardless of country of manufacture; or
(ii) To a UN standard, for packagings manufactured within the United States. For UN standard packagings manufactured outside the United States, see § 173.24(d)(2) of this subchapter. For UN standard packagings for which standards are not prescribed in this part, see § 178.3(b).
(2) A manufacturer of a packaging subject to the requirements of this part is primarily responsible for compliance with the requirements of this part. However, any person who performs a function prescribed in this part shall perform that function in accordance with this part.
(b) Specification markings. When this part requires that a packaging be marked with a DOT specification or UN standard marking, marking of the packaging with the appropriate DOT or UN markings is the certification that -
(1) Except as otherwise provided in this section, all requirements of the DOT specification or UN standard, including performance tests, are met; and
(2) All functions performed by, or on behalf of, the person whose name or symbol appears as part of the marking conform to requirements specified in this part.
(c) Notification. (1) Except as specifically provided in §§ 178.337-18, 178.338-19, and 178.345-15 of this part, the manufacturer or other person certifying compliance with the requirements of this part, and each subsequent distributor of that packaging must:
(i) Notify each person to whom that packaging is transferred -
(A) Of all requirements in this part not met at the time of transfer, and
(B) With information specifying the type(s) and dimensions of the closures, including gaskets and any other components needed to ensure that the packaging is capable of successfully passing the applicable performance tests. This information must include any procedures to be followed, including closure instructions for inner packagings and receptacles, to effectively assemble and close the packaging for the purpose of preventing leakage in transportation. Closure instructions must provide for a consistent and repeatable means of closure that is sufficient to ensure the packaging is closed in the same manner as it was tested. For packagings sold or represented as being in conformance with the requirements of this subchapter applicable to transportation by aircraft, this information must include relevant guidance to ensure that the packaging, as prepared for transportation, will withstand the pressure differential requirements in § 173.27 of this subchapter.
(ii) Retain copies of each written notification for at least one year from date of issuance; and
(iii) Make copies of all written notifications available for inspection by a representative of the Department.
(2) The notification required in accordance with this paragraph (c) may be in writing or by electronic means, including e-mailed transmission or transmission on a CD or similar device. If a manufacturer or subsequent distributor of the packaging utilizes electronic means to make the required notifications, the notification must be specific to the packaging in question and must be in a form that can be printed in hard copy by the person receiving the notification.
(d) Except as provided in paragraph (c) of this section, a packaging not conforming to the applicable specifications or standards in this part may not be marked to indicate such conformance.
(e) Definitions. For the purpose of this part -
Manufacturer means the person whose name and address or symbol appears as part of the specification markings required by this part or, for a packaging marked with the symbol of an approval agency, the person on whose behalf the approval agency certifies the packaging.
Specification markings mean the packaging identification markings required by this part including, where applicable, the name and address or symbol of the packaging manufacturer or approval agency.
(f) No packaging may be manufactured or marked to a packaging specification that was in effect on September 30, 1991, and that was removed from this part 178 by a rule published in the
(a) Each packaging represented as manufactured to a DOT specification or a UN standard must be marked on a non-removable component of the packaging with specification markings conforming to the applicable specification, and with the following:
(1) In an unobstructed area, with letters, and numerals identifying the standards or specification (e.g. UN 1A1, DOT 4B240ET, etc.).
(2) Unless otherwise specified in this part, the name and address or symbol of the packaging manufacturer or the person certifying compliance with a UN standard. Symbols, if used, must be registered with the Associate Administrator. Unless authorized in writing by the holder of the symbol, symbols must represent either the packaging manufacturer or the approval agency responsible for providing the most recent certification for the packaging through design certification testing or periodic retesting, as applicable. Duplicative symbols are not authorized.
(3) The markings must be stamped, embossed, burned, printed or otherwise marked on the packaging to provide adequate accessibility, permanency, contrast, and legibility so as to be readily apparent and understood.
(4) Unless otherwise specified, letters and numerals must be at least 12.0 mm (0.47 inches) in height except that for packagings of less than or equal to 30 L (7.9 gallons) capacity for liquids or 30 kg (66 pounds) capacity for solids the height must be at least 6.0 mm (0.2 inches). For packagings having a capacity of 5 L (1 gallon) or 5 kg (11 pounds) or less, letters and numerals must be of an appropriate size.
(5) For packages with a gross mass of more than 30 kg (66 pounds), the markings or a duplicate thereof must appear on the top or on a side of the packaging.
(b) A UN standard packaging for which the UN standard is set forth in this part may be marked with the United Nations symbol and other specification markings only if it fully conforms to the requirements of this part. A UN standard packaging for which the UN standard is not set forth in this part may be marked with the United Nations symbol and other specification markings for that standard as provided in the ICAO Technical Instructions or the IMDG Code subject to the following conditions:
(1) The U.S. manufacturer must establish that the packaging conforms to the applicable provisions of the ICAO Technical Instructions (IBR, see § 171.7 of this subchapter) or the IMDG Code (IBR, see § 171.7 of this subchapter), respectively.
(2) If an indication of the name of the manufacturer or other identification of the packaging as specified by the competent authority is required, the name and address or symbol of the manufacturer or the approval agency certifying compliance with the UN standard must be entered. Symbols, if used, must be registered with the Associate Administrator.
(3) The letters “USA” must be used to indicate the State authorizing the allocation of the specification marks if the packaging is manufactured in the United States.
(c) Where a packaging conforms to more than one UN standard or DOT specification, the packaging may bear more than one marking, provided the packaging meets all the requirements of each standard or specification. Where more than one marking appears on a packaging, each marking must appear in its entirety.
(d) No person may mark or otherwise certify a packaging or container as meeting the requirements of a manufacturing special permit unless that person is the holder of or a party to that special permit, an agent of the holder or party for the purpose of marking or certification, or a third party tester.
Subpart J [§ 178.318 - § 178.348-5] - Specifications for Containers for Motor Vehicle Transportation
Subpart K [§ 178.350 - § 178.350] - Specifications for Packagings for Class 7 (Radioactive) Materials
[Open-hearth, basic oxygen, or electric steel of uniform quality. The following chemical composition limits are based on ladle analysis:]
|Designation||Chemical composition, percent-ladle analysis|
|Grade 1 1||Grade 2 1 2||Grade 3 2 4 5|
|Carbon||0.10/0.20||0.24 maximum||0.22 maximum.|
|Phosphorus, maximum||0.04||0.04||0.045. 6|
|Heat treatment authorized||( 3)||( 3)||( 3).|
|Maximum stress (p.s.i.)||35,000||35,000||35,000.|
1 Addition of other elements to obtain alloying effect is not authorized.
2 Ferritic grain size 6 or finer according to ASTM E 112-96 (IBR, see § 171.7 of this subchapter).
3 Any suitable heat treatment in excess of 1,100 °F., except that liquid quenching is not permitted.
4 Other alloying elements may be added and shall be reported.
5 For compositions with a maximum carbon content of 0.15 percent of ladle analysis, the maximum limit for manganese on ladle analysis may be 1.40 percent.
6 Rephosphorized Grade 3 steels containing no more than 0.15 percent phosphorus are permitted if carbon content does not exceed 0.15 percent and manganese does not exceed 1 percent.
Check Analysis Tolerances
[A heat of steel made under any of the above grades, the ladle analysis of which is slightly out of the specified range is acceptable if the check analysis is within the following variations:]
|Element||Limit or maximum specified (percent)||Tolerance (percent) over the maximum limit or under the minimum limit|
|Under minimum limit||Over maximum limit|
|Carbon||To 0.15 inclusive||0.02||0.03|
|Over 0.15 to 0.40 inclusive||0.03||0.04|
|Manganese||To 0.60 inclusive||0.03||0.03|
|Over 0.60 to 1.15 inclusive||0.04||0.04|
|Over 1.15 to 2.50 inclusive||0.05||0.05|
|Phosphorus 7||All ranges||0.01|
|Silicon||To 0.30 inclusive||0.02||0.03|
|Over 0.30 to 1.00 inclusive||0.05||0.05|
|Copper||To 1.00 inclusive||0.03||0.03|
|Over 1.00 to 2.00 inclusive||0.05||0.05|
|Nickel||To 1.00 inclusive||0.03||0.03|
|Over 1.00 to 2.00 inclusive||0.05||0.05|
|Chromium||To 0.90 inclusive||0.03||0.03|
|Over 0.90 to 2.10 inclusive||0.05||0.05|
|Molybdenum||To 0.20 inclusive||0.01||0.01|
|Over 0.20 to 0.40 inclusive||0.02||0.02|
|Columbium||To 0.04 inclusive||0.005||0.01|
|Aluminum||Over 0.10 to 0.20 inclusive||0.04||0.04|
|Over 0.20 to 0.30 inclusive||0.05||0.05|
7 Rephosphorized steels not subject to check analysis for phosphorus.
In addition to the method prescribed in § 178.604 of this subchapter, the following leakproofness test methods are authorized:
(1) Helium test. The packaging must be filled with at least 1 L inert helium gas, air tight closed, and placed in a testing chamber. The testing chamber must be evacuated down to a pressure of 5 kPa which equals an over-pressure inside the packaging of 95 kPa. The air in the testing chamber must be analyzed for traces of helium gas by means of a mass spectrograph. The test must be conducted for a period of time sufficient to evacuate the chamber and to determine if there is leakage into or out of the packaging. If helium gas is detected, the leaking packaging must be automatically separated from non-leaking drums and the leaking area determined according to the method prescribed in § 178.604(d) of this subchapter. A packaging passes the test if there is no leakage of helium.
(2) Pressure differential test. The packaging shall be restrained while either pressure or a vacuum is applied internally. The packaging must be pressurized to the pressure required by § 178.604(e) of this subchapter for the appropriate packing group. The method of restraint must not affect the results of the test. The test must be conducted for a period of time sufficient to appropriately pressurize or evacuate the interior of the packaging and to determine if there is leakage into or out of the packaging. A packaging passes the pressure differential test if there is no change in measured internal pressure.
(3) Solution over seams. The packaging must be restrained while an internal air pressure is applied; the method of restraint may not affect the results of the test. The exterior surface of all seams and welds must be coated with a solution of soap suds or a water and oil mixture. The test must be conducted for a period of time sufficient to pressurize the interior of the packaging to the specified air pressure and to determine if there is leakage of air from the packaging. A packaging passes the test if there is no leakage of air from the packaging.
(4) Solution over partial seams test. For other than design qualification testing, the following test may be used for metal drums: The packaging must be restrained while an internal air pressure of 48 kPa (7.0 psig) is applied; the method of restraint may not affect the results of the test. The packaging must be coated with a soap solution over the entire side seam and a distance of not less than eight inches on each side of the side seam along the chime seam(s). The test must be conducted for a period of time sufficient to pressurize the interior of the packaging to the specified air pressure and to determine if there is leakage of air from the packaging. A packaging passes the test if there is no leakage of air from the packaging. Chime cuts must be made on the initial drum at the beginning of each production run and on the initial drum after any adjustment to the chime seamer. Chime cuts must be maintained on file in date order for not less than six months and be made available to a representative of the Department of Transportation on request.
Appendix Appendix C - Appendix C to Part 178 - Nominal and Minimum Thicknesses of Steel Drums and Jerricans
For each listed packaging capacity, the following table compares the ISO 3574 (IBR, see § 171.7 of this subchapter) nominal thickness with the corresponding ISO 3574 minimum thickness.
|Maximum capacity (L)||ISO nominal (mm)||Corresponding ISO minimum (mm)|
1. Scope. This test method evaluates the thermal resistance capabilities of a compressed oxygen generator and the outer packaging for a cylinder of compressed oxygen or other oxidizing gas and an oxygen generator. When exposed to a temperature of 205 °C (400 °F) for a period of not less than three hours, the outer surface of the cylinder may not exceed a temperature of 93 °C (199 °F) and the oxygen generator must not actuate.
2.1 Test Oven. The oven must be large enough in size to fully house the test outer package without clearance problems. The test oven must be capable of maintaining a minimum steady state temperature of 205 °C (400 °F).
2.2 Thermocouples. At least three thermocouples must be used to monitor the temperature inside the oven and an additional three thermocouples must be used to monitor the temperature of the cylinder. The thermocouples must be
2.3 Instrumentation. A calibrated recording device or a computerized data acquisition system with an appropriate range should be provided to measure and record the outputs of the thermocouples.
3. Test Specimen.
3.1 Specimen Configuration. Each outer package material type and design must be tested, including any features such as handles, latches, fastening systems, etc., that may compromise the ability of the outer package to provide thermal protection.
3.2 Test Specimen Mounting. The tested outer package must be supported at the four corners using fire brick or other suitable means. The bottom surface of the outer package must be exposed to allow exposure to heat.
4. Preparation for Testing.
4.1 It is recommended that the cylinder be closed at ambient temperature and configured as when filled with a valve and pressure relief device. The oxygen generator must be filled with an oxidizing agent and may be tested with or without packaging.
4.2 Place the package or generator onto supporting bricks or a stand inside the test oven in such a manner to ensure even temperature flow.
5. Test Procedure.
5.1 Close oven door and check for proper reading on thermocouples.
5.2 Raise the temperature of the oven to a minimum temperature of 205 °C ±2 °C (400 °F ±5 °F). Maintain a minimum oven temperature of 205 °C ±2 °C (400 °F ±5 °F) for at least three hours. Exposure time begins when the oven steady state temperature reaches a minimum of 205 °C ±2 °C (400 °F ±5 °F).
5.3 At the conclusion of the three-hour period, the outer package may be removed from the oven and allowed to cool naturally.
6.1 Record a complete description of the material being tested, including the manufacturer, size of cylinder, etc.
6.2 Record any observations regarding the behavior of the test specimen during exposure, such as smoke production, delamination, resin ignition, and time of occurrence of each event.
6.3 Record the temperature and time history of the cylinder temperature during the entire test for each thermocouple location. Temperature measurements must be recorded at intervals of not more than five (5) minutes. Record the maximum temperatures achieved at all three thermocouple locations and the corresponding time.
7.1 For a cylinder, the outer package must provide adequate protection such that the outer surface of the cylinder and valve does not exceed a temperature of 93 °C (199 °F) at any of the three points where the thermocouples are located.
7.2 For an oxygen generator, the generator must not actuate.
(a) Criteria for Acceptance. (1) At least three specimens of the outer packaging materials must be tested;
(2) Each test must be conducted on a flat 16 inch × 24 inch test specimen mounted in the horizontal ceiling position of the test apparatus to represent the outer packaging design;
(3) Testing must be conducted on all design features (latches, seams, hinges, etc.) affecting the ability of the outer packaging to safely prevent the passage of fire in the horizontal ceiling position; and
(4) There must be no flame penetration of any specimen within 5 minutes after application of the flame source and the maximum allowable temperature at a point 4 inches above the test specimen, centered over the burner cone, must not exceed 205 °C (400 °F).
(b) Summary of Method. This method provides a laboratory test procedure for measuring the capability of cargo compartment lining materials to resist flame penetration with a 2 gallon per hour (GPH) #2 Grade kerosene or equivalent burner fire source. Ceiling and sidewall liner panels may be tested individually provided a baffle is used to simulate the missing panel. Any specimen that passes the test as a ceiling liner panel may be used as a sidewall liner panel.
(c) Test Specimens. (1) The specimen to be tested must measure 16 ±
(2) The specimens must be conditioned at 70 °F. ±5 °F. (21 °C. ±2 °C.) and 55% ±5% humidity for at least 24 hours before testing.
(d) Test Apparatus. The arrangement of the test apparatus must include the components described in this section. Minor details of the apparatus may vary, depending on the model of the burner used.
(1) Specimen Mounting Stand. The mounting stand for the test specimens consists of steel angles.
(2) Test Burner. The burner to be used in tesing must -
(i) Be a modified gun type.
(ii) Use a suitable nozzle and maintain fuel pressure to yield a 2 GPH fuel flow. For example: An 80 degree nozzle nominally rated at 2.25 GPH and operated at 85 pounds per square inch (PSI) gauge to deliver 2.03 GPH.
(iii) Have a 12 inch (305 mm) burner extension installed at the end of the draft tube with an opening 6 inches (152 mm) high and 11 inches (280 mm) wide.
(iv) Have a burner fuel pressure regulator that is adjusted to deliver a nominal 2.0 GPH of #2 Grade kerosene or equivalent.
Burner models which have been used successfully in testing are the Lenox Model OB-32, Carlin Model 200 CRD and Park Model DPL.
(3) Calorimeter. (i) The calorimeter to be used in testing must be a total heat flux Foil Type Gardon Gage of an appropriate range (approximately 0 to 15.0 British thermal unit (BTU) per ft.
(ii) The insulating block must be monitored for deterioration and the mounting shimmed as necessary to ensure that the calorimeter face is parallel to the exit plane of the test burner cone.
(4) Thermocouples. The seven thermocouples to be used for testing must be
(5) Apparatus Arrangement. The test burner must be mounted on a suitable stand to position the exit of the burner cone a distance of 8 inches from the ceiling liner panel and 2 inches from the sidewall liner panel. The burner stand should have the capability of allowing the burner to be swung away from the test specimen during warm-up periods.
(6) Instrumentation. A recording potentiometer or other suitable instrument with an appropriate range must be used to measure and record the outputs of the calorimeter and the thermocouples.
(7) Timing Device. A stopwatch or other device must be used to measure the time of flame application and the time of flame penetration, if it occurs.
(e) Preparation of Apparatus. Before calibration, all equipment must be turned on and allowed to stabilize, and the burner fuel flow must be adjusted as specified in paragraph (d)(2).
(f) Calibration. To ensure the proper thermal output of the burner the following test must be made:
(1) Remove the burner extension from the end of the draft tube. Turn on the blower portion of the burner without turning the fuel or igniters on. Measure the air velocity using a hot wire anemometer in the center of the draft tube across the face of the opening. Adjust the damper such that the air velocity is in the range of 1550 to 1800 ft./min. If tabs are being used at the exit of the draft tube, they must be removed prior to this measurement. Reinstall the draft tube extension cone.
(2) Place the calorimeter on the test stand as shown in Figure 2 at a distance of 8 inches (203 mm) from the exit of the burner cone to simulate the position of the horizontal test specimen.
(3) Turn on the burner, allow it to run for 2 minutes for warm-up, and adjust the damper to produce a calorimeter reading of 8.0 ±0.5 BTU per ft.
(4) Replace the calorimeter with the thermocouple rake.
(5) Turn on the burner and ensure that each of the seven thermocouples reads 1700 °F. ±100 °F. (927 °C. ±38 °C.) to ensure steady state conditions have been achieved. If the temperature is out of this range, repeat steps 2 through 5 until proper readings are obtained.
(6) Turn off the burner and remove the thermocouple rake.
(7) Repeat (1) to ensure that the burner is in the correct range.
(g) Test Procedure. (1) Mount a thermocouple of the same type as that used for calibration at a distance of 4 inches (102 mm) above the horizontal (ceiling) test specimen. The thermocouple should be centered over the burner cone.
(2) Mount the test specimen on the test stand shown in Figure 1 in either the horizontal or vertical position. Mount the insulating material in the other position.
(3) Position the burner so that flames will not impinge on the specimen, turn the burner on, and allow it to run for 2 minutes. Rotate the burner to apply the flame to the specimen and simultaneously start the timing device.
(4) Expose the test specimen to the flame for 5 minutes and then turn off the burner. The test may be terminated earlier if flame penetration is observed.
(5) When testing ceiling liner panels, record the peak temperature measured 4 inches above the sample.
(6) Record the time at which flame penetration occurs if applicable.
(h) Test Report. The test report must include the following:
(1) A complete description of the materials tested including type, manufacturer, thickness, and other appropriate data.
(2) Observations of the behavior of the test specimens during flame exposure such as delamination, resin ignition, smoke, etc., including the time of such occurrence.
(3) The time at which flame penetration occurs, if applicable, for each of the three specimens tested.