Specific requirements apply for the packaging of dangerous goods products for their transport by road, rail, air and sea. The packaging requirements differ depending on the mode of transport, with the most stringent packaging requirements applying to air transport.
This article discusses the packaging requirements that apply to the transport of dangerous goods by road and rail in Australia. Generally, dangerous goods cannot be transported in just any general packaging and are required to be packed in packaging which complies with the requirements. Packaging requirements specify the minimum standards for the packaging of dangerous goods, to ensure their safe transport. Dangerous goods packaging which does not comply with the regulations, can leak during transport, or may react with other products, placing the health and safety of persons at risk. It is critical dangerous goods are transported in packaging which complies with the requirements.
In Victoria, the packaging of dangerous goods for transport is governed by the the Dangerous Goods (Transport by road or rail) Regulations 2018 (Vic) (‘regulations’). This regulation imposes duties for packaging on consignors, packers, loaders, rail operators, transport operators, prime contractors and drivers. The technical packaging requirements for the transport of dangerous goods by road or rail are detailed in the Australian Code for the Transport of Dangerous Goods by Road & Rail (‘ADG Code’). The main duties in relation to the packaging of dangerous goods by road and rail are:
- A person must not consign or pack dangerous goods for transport in any general packaging if the person knows or reasonably ought to know that the packaging is unsuitable for the transport of dangerous goods.
- A person must not consign or pack dangerous goods for transport in any general packaging if the person knows or reasonably ought to know, that the goods have not been packed in accordance with any relevant provision of the ADG Code.
- A person must not load dangerous goods that are in any general packaging onto a vehicle for transport, if the person knows or reasonably ought to know, that the packaging is damaged or defective. This duty also applies to prime contractors, rail operators and drivers.
General Packaging Requirements
The general provisions apply to the transport of dangerous goods that are not transported under the exceptions. General provisions allow for the highest weight of dangerous goods to be transported per package compared to the exceptions. However, the general provisions provide for the most stringent packaging requirements under the ADG. The packaging requirements are dependent on the type of dangerous goods being transported, its quantity and its packing group.
The outer packaging is required to be constructed from the specified materials as stated in the packing instruction of the respective dangerous goods. This may include the requirement to being constructed from materials such as, fibreboard, plastic, steel, aluminium, other metals, natural wood, plywood, or reconstituted wood. There are also requirements for the material for the construction of the inner packaging, which is often required to be manufactured from plastic, glass or metal.
The packaging for transport under the general provisions is required to comply with extensive provisions. An extract of some of the applicable provisions of the ADG is provided below. Note these are not the full provisions and should not be relied on as such.
“Dangerous Goods must be packed in good quality packaging, which must be strong enough to withstand the shocks and loadings normally encountered during transport. Packaging must be constructed and closed to prevent any loss of contents during transport. Packaging must not contain dangerous residue on the outside of packages during transport.”
“Packaging which is in direct contact with dangerous goods, must not be:
Affected or significantly weakened by those dangerous goods
Must not cause a dangerous effect or react with dangerous goods
Must not allow permeation of the dangerous goods that could constitute a danger under normal conditions of transport
Where necessary, they must be provided with a suitable inner coating or treatment”
“Inner packaging must be packed in an outer packaging in such a way that under normal conditions of transport they cannot break, be punctured or leak their contents into the outer packaging.
Inner packaging containing liquids must be packaged with their closures upwards and placed within outer packaging consistent with any orientation marks.
Inner packaging that is liable to break or be punctured easily, such as those made of glass, porcelain, stoneware or of certain plastics must be secured in outer packaging with suitable cushioning material. Any leakage of the contents must not substantially impair the protective properties of the cushioning materials or of the outer packaging.”
“Dangerous goods must not be packed together in the same outer packaging or in large packaging, with dangerous or other goods if they react dangerously with each other and cause:
Combustion and or evolution of considerable heat
Evolution of flammable, toxic or asphyxiant gases
Formation of corrosive substances
Formation of unstable substances”
“Where pressure may develop in a package by the emission of gas from the contents, the packaging or IBC may be fitted with a vent, provided that the gas emitted will not cause danger on account of its toxicity, its flammability or its quantity released.”
Testing of Packaging
When transporting dangerous goods under the general provisions for road and rail transport, the outer packaging is required to undergo testing to ensure it complies with the requirements. This includes the following testing, drop test, leakproofness test, internal pressure test, stacking test. A test report confirming the tests have been carried out is required to be available for users of the packaging. Dangerous goods packaging used under the general provisions is required to be marked with the United Nations packaging symbol and the required information, which certifies the packaging complies with the testing requirements.
There are two main types of exceptions which can allow dangerous goods to be transported with less stringent packing requirements than the general requirements. The rationale is the risk of harm to persons or property is reduced where the dangerous goods are packed in small quantities in good quality packaging. These exceptions are the limited quantities provisions and the excepted quantities provisions. Limited quantities provisions allow for a greater quantity of dangerous goods to be transported compared with excepted quantities provisions. Both exceptions are suited for the transport of dangerous goods packed in retail packaging for consumer use.
Limited Quantities Provisions
Limited quantities provisions are stated under Chapter 3.4 of the ADG. Dangerous goods may be transported under the limited quantities provisions if the dangerous goods being transported has a limited quantity under the dangerous goods list and the dangerous goods being transported complies with that quantity.
The packaging is required to comply with provisions 184.108.40.206, 220.127.116.11, 18.104.22.168 to 22.214.171.124 of the ADG.
The packaging is required to comply with provision 6.1.4 of the ADG and be constructed from the approved materials as required under the general provisions. The maximum weight for transport of a single package under the limited quantities provisions is limited to a maximum of 30kg and 20kg, where the inner packaging is liable to break or be easily punctured. (e.g. where made from glass). Inner packaging is compulsory except for aerosols or small receptacles containing gas. Intermediate packaging is compulsory for class 8 liquids of packing group 2, which have inner packaging of glass, porcelain, or stoneware.
Under the limited quantities provisions for the transport of road and rail, the package is not required to undergo testing to comply with the performance tests as required under the general provisions. However note, air transport regulations differ in this area and there are certain package performance tests that apply for air transport under limited quantities provisions. The package testing required for air transport under limited quantities provisions includes, drop test, 24 hour stacking test and pressure differential test for liquids. This means packages packed for air transport must be packed in packaging which comply with this testing. Under limited quantities provisions for road and rail transport, packages are also exempt from the markings required on packaging to certify the packaging has been tested and complies with the requirements.
Excepted Quantities Provisions
Excepted quantities provisions are stated under Chapter 3.5 of the ADG. Excepted quantities provisions allow for the transport of dangerous goods with less stringent requirements than the general provisions, however in smaller quantities than the limited quantity provisions. The maximum quantities of dangerous goods permitted for transport under the excepted quantities provisions, depends upon the class of dangerous goods and their designation to the respective code. Dangerous goods are assigned to the following codes:
There are specific packing requirements for dangerous goods under the excepted quantities provisions. Inner packaging is required, which is required to be constructed of plastic or glass, porcelain, stoneware, earthenware or metal and the closure of each inner packaging is required to be held securely in place with wire, tape, or other positive means. The dangerous goods are required to comply with the other requirements of provision 3.5.2.
The outer packaging for transport under the excepted provisions is required to be of strong rigid outer packaging such as wooden, fibreboard, or other equally strong material.
Unlike the limited quantities provisions, dangerous goods packages shipped under the excepted quantities provisions are required to undergo a drop test and a 24 hour stacking test for transport by road and rail.
Application of Packaging Requirements
In this example we will apply the road and rail packaging requirements to a dangerous goods product that is classified as UN 1993 Flammable Liquid N.O.S, packing group 3 and is a liquid, packed in 3 litre plastic retail inner packaging.
To determine the packaging requirements, we need to look up UN 1993 in the dangerous goods list contained in Chapter 3.2 of the ADG.
The dangerous goods list provides the following information for UN 1993 packing group 3:
The maximum quantity permitted under the limited quantities is 5L. The maximum quantity permitted under the excepted quantities is 30 ml per inner packaging and 1L per outer packaging. Our product exceeds the excepted quantities limits and cannot be transported under these provisions. The product can be shipped under the limited quantities provisions and the general provisions.
The other information to note in this table is any special provisions that apply to the product. Special provisions are provisions which prescribe specific requirements for dangerous goods. This may include exceptions, marking, documentation, packing instructions, or other requirements.
For our product we have two special provisions that apply, SP 223 and SP 274. The list of special provisions are contained in Chapter 3.3 of the ADG.
SP 223 provides:
“If the chemical or physical properties of a substance covered by this description are such that when tested it does not meet the established defining criteria for the Class or division listed in column (3), or any other Class or division, it is not subject to this Code.”
This special provision is an exception and means if the product does not meet the classification requirements of class 3 dangerous goods (flammable liquids), it is exempt from the ADG requirements for road and rail. The classification criteria for class 3 dangerous goods is contained in Chapter 2.3 of the ADG. For a product to be classified as class 3, it must have a flash point of less than 60° C (closed cup test) or 65.6° C (open cup test). We will assume the flash point of our product is less than these limits and is a class 3 dangerous goods. Therefore, the special provision 223 exception will not apply.
SP 274 provides:
“For the purposes of documentation and package marking, the proper shipping name must be supplemented with the technical name”.
As our shipping name of the product is UN 1993 Flammable Liquid N.O.S, which is generic, it must be supplemented with the technical name. The technical name will depend upon the class 3 ingredients in the product. If the class 3 ingredient in our product was benzene, the technical name would be as follows, ‘UN 1993 Flammable Liquid N.O.S (contains benzene)’.
The packaging instruction listed in the final column of the table provides specific information as to how the product must be packaged. The packaging instruction for P001 is contained in Chapter 4.1 of the ADG. The packaging instruction provides information as to the type of inner and outer packaging permitted, the maximum quantity permitted for that packaging type and any special packaging provision that applies.
For our product, the inner packaging is required to be made from glass, plastics, or metal. The box for the outer packaging is required to be made from steel, aluminum, other metals, natural wood, fibreboard, plywood, reconstituted wood, expanded plastics, and solid plastics. Our inner packaging is made from plastic and we will assume the outer packaging is constructed from fibreboard. The maximum weight of the package permitted for this combination is 400 kg for a product of packing group 3.
Our package can be transported under the limited quantities provisions, as it is in retail packaging with a quantity of less than 5L. The package will need to be shipped as per the limited quantities provisions contained in Chapter 3.4 of the ADG and discussed above. The maximum weight of the package permitted under limited quantities is 30kg for inner packaging which is not prone to breaking, such as plastic. Under limited provisions, the dangerous goods do not require to be transported in packaging which has been tested and is compliant for road and rail transport.
The package can also be shipped under the general provisions. The advantage of transporting this package under the general provisions is, that the maximum weight of the package can be increased to 400kg, which can reduce transportation costs. However, general provisions are more stringent compared to limited quantities provisions, due to the increased risk. The product will require to be packaged in packaging which has been tested as per the requirements under the general provisions.
In conclusion, the requirements for the packaging of dangerous goods can be complex. Duty holders should ensure they have controls in place to comply with their duties. This may include implementing the following controls:
- Identifying and assessing packaging requirements for dangerous goods
- Implementing systems to ensure dangerous goods are transported in compliant packaging
- Monitoring compliance to packaging requirements
- Providing regular training to persons involved in packing and transport of dangerous goods on the packaging requirements
- Reviewing compliance to packaging requirements through audits or other means and implementing actions to ensure continuous improvement
 Dangerous Goods (Transport by road or rail) Regulations 2018 (Vic) sections 61, 62.
 ibid sections 61,62.
 ibid section 63.
 ibid sections 64, 65.
 Australian Code for the Transport of Dangerous Goods by Road & Rail Edition 7.8 (2022) provision 6.1.5.
 ibid provision 126.96.36.199.
 ibid provision 6.1.4.
 ibid provision 188.8.131.52.
 ibid provision 184.108.40.206.
 ibid provision 220.127.116.11
 ibid provision 18.104.22.168
 Provision 3.5.2.
 ibid provision 3.5.3.
 ibid provision 3.3.2 sp 223.
 ibid provision 22.214.171.124
 ibid provision 3.3.2 sp 274.