Guidance

Arrangements for the performance testing, certification and marking of packagings

Updated 6 April 2020

1. Introduction

These arrangements summarise the national and international recommendations and regulations for the transport of dangerous goods relating to packagings, including packages, large packagings and intermediate bulk containers (IBCs).

They follow the recommendations in chapters 6.1, 6.3, 6.5 and 6.6 of the UN Recommendations on the Transport of Dangerous Goods (Transport of Dangerous Goods – Model Regulations (21st Edition) and set out the arrangements applicable to the performance testing, certification and marking of new packagings.

This document replaces the arrangements published in June 2001 as WP/TDG/(01)/(120). It follows a change in the arrangements for package certification.

Since 1 April 2007 the Vehicle Certification Agency Dangerous Goods Office (VCADGO) operates the scheme on behalf of the Department for Transport.

2. Background

2.1 The UN Sub Committee of Experts on the Transport of Dangerous Goods publishes recommendations addressed to governments and to the international organisations concerned with the regulation of the transport of dangerous goods, with the intention that they might form the basis for national and international requirements.

The recommendations form the basis of the provisions in:

• RID (Regulations concerning the International Carriage of Dangerous Goods by Rail)
• ADR (European Agreement concerning the International Carriage of Dangerous Goods by Road)
• the IMDG Code (International Maritime Dangerous Goods Code)
• the ICAO TIs (Technical Instructions for the Safe Transport of Dangerous Goods by Air)

along with the associated domestic regulations.

They provide a framework applicable to all modes of transport, thereby facilitating the adoption of uniform provisions in the agreements and regulations which govern the separate modes.

2.2 The recommendations in chapters 6.1, 6.3, 6.5, 6.6 of the 21st edition of the UN document include specifications for each of the main types of packagings, performance tests devised to ensure that packagings will be sufficiently robust to withstand the normal risks of transport, the affixation of a packaging symbol, and other marks which can be placed on packages conforming to the recommendations.

2.3 The recommendations are revised every 2 years. Their relevant provisions (as amended) are referred to domestically in the corresponding Carriage of Dangerous Goods Regulations (currently the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 SI 1348).

3. Adoption of the UN recommendations and international requirements

3.1 Chapter 6.1

The provisions of chapter 6.1 apply to most packing instructions (P Nos) in part 4 of the relevant regulations.

ADR - the Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 (SI 2009: 1348), which cover transport in Great Britain, provide some limited exemptions for vehicles travelling under ADR.

RID - RID is an appendix (Appendix C) to the COTIF Convention which was enacted in the UK under the International Transport Conventions Act 1983.

Carriage of packaged dangerous goods by air is governed by the Air Navigation (Dangerous Goods) Regulations 2019 (SI 2019, No.922)(as amended).

These will give effect to the ICAO (International Civil Aviation Organisation) Technical Instructions – 2017/2018 Edition, which are mandatory under the regulations. Packagings for most substances are required to comply with instructions similar to the recommendations of chapter 6.1.

Carriage of packaged dangerous goods by sea is governed by the Merchant Shipping (Dangerous Goods and Marine Pollutants) Regulations (SI 1997:2605).

Package performance testing is prescribed under the Regulations and set out in detail in International Maritime Dangerous Goods (IMDG) Code.

3.2 Chapter 6.3

ADR, RID, the IMDG Code and the ICAO Technical Instructions contain provisions relating to Class 6.2 Infectious substances of Category A.

3.3 Chapter 6.5

ADR, RID and the IMDG Code contain provisions relating to IBCs based on chapter 6.5. The carriage of dangerous substances in IBCs is not provided for in the ICAO Technical Instructions.

3.4 Chapter 6.6

ADR, RID and the IMDG Code contain provisions relating to large packagings based on chapter 6.6. The provisions apply to most large packing instructions (LP Nos) in part 4 of the relevant regulations. The carriage of dangerous substances in large packagings is not provided for in the ICAO Technical Instructions.

3.5 Testing

The testing required by chapter 6.1, 6.3, 6.5 and 6.6 of the UN Recommendations is the same as that in the equivalent chapters of ADR, RID, IMDG Code and ICAO Technical Instructions. ADR and RID contain supplementary requirements that compatibility of plastic packaging material is taken into account (ADR 6.1.5.2.5). The result is that a UN mark on the package is normally acceptable under all modes.

The various regulations and recommendations mentioned above provide for exemptions in full or in part from the performance test requirements for dangerous goods in small quantities. For the relevant details it is necessary to consult the applicable publication.

4. Transport within the UK

4.1 For transport within the United Kingdom, consignors must ensure that they comply with the legal requirements regulating packaging standards. The position on packaging performance testing for the various modes of transport is presently as follows:

4.2 Road transport and rail transport

The Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations 2009 came into force on 1 July 2009.

4.3 Air Transport

The requirements for air transport within the UK are identical to the international regulations described in 5(c) above.

4.4 Sea transport

The requirements for marine transport within UK territorial waters are identical to the international requirements described in 5(d) above.

5. UK implementation of chapters 6.1, 6.3 and 6.6 of the UN recommendations

5.1 Applicability

The arrangements in this document are applicable to the UN performance testing and marking of packagings by the UK, irrespective of the mode by which they may be transported. With the exception of the majority of Class 2 and Class 7 substances, they are applicable to all substances classified as dangerous goods for transport purposes. The arrangements are also applicable to RID/ADR performance testing and marking of certain packagings (light gauge metal packages) for which RID/ADR markings are required.

Consignors should, as generally provided in the recommendations and regulations, always ensure that the packaging used for dangerous goods is compatible with the proposed contents (chapter 4.1 of the various regulations refers). Particularly in the case of plastics, receptacles and packagings, they should be compatible with the contents and have an adequate degree of resistance to permeation. ADR/RID include a method of assessing compatibility of HDPE plastics (see 4.1.1.21) by using standard liquids.

5.2 Testing in the United Kingdom

Tests intended to lead to the issue of a certificate which allocates the UN mark for a particular type of packaging are carried out only by test stations authorised for the purpose. A number of test stations are so authorised and any suitably qualified laboratory can be authorised as a test station if they wish. A list of current test stations is obtainable on request from DfT or VCADGO. Authorisation covers the quality of testing but not the detailed procedure to be followed in each instance, application of the results etc.

Authorised test stations are only those accredited by the United Kingdom Accreditation Service (UKAS) for this purpose. Fees for accreditation are a matter for arrangement between UKAS and the applicant. Applications should be addressed to:

UKAS,
2 Pine Trees
Chertsey Lane
Staines-upon-Thames
TW18 3HR

Authorised test stations must operate in accordance with the accreditation standard and relevant regulations. In addition, for their test reports to be acceptable as the basis for issue of a certificate, they must operate in accordance with the current version of the document entitled ‘Operational Instructions for Test Stations’, available from VCADGO.

5.3 Certification (approvals)

In common with most countries, issue of certificates, on the basis of successful test reports, is carried out centrally by an officially appointed certifying body. The department has appointed VCADGO to carry out this certification function.

Reports of successful tests from test stations authorised as in paragraph 5.2.3 must be submitted to VCADGO for the allocation of an official certificate allocating packaging markings.

The certificates issued by VCADGO remain the property of the department, they are not transferable. Certificates may be cancelled by the current holder or by VCADGO when the company is sold or goes into liquidation. In the event of cancellation, the department requires the original of the certificate(s) to be returned to VCADGO. In such circumstances the information will be made available to the department. In any other circumstance e.g. misuse of a certificate, cancellation will only be carried out on the authority of the Department for Transport.

5.4 Purpose of marking

The UN mark indicates that the package which bears it corresponds to a successfully tested design type and that it complies with the provisions of chapter 6.1, 6.3, 6.5 or chapter 6.6 which are related to the manufacture, but not to the use of the packaging. In itself, therefore, the mark does not necessarily confirm that the packaging may be used for any substance. The marking is intended to be of assistance to packaging manufacturers, packaging users, carriers and regulatory authorities. In relation to the use of a new packaging the original marking is a means for its manufacturer(s) to identify the type and to indicate those performance test requirements that have been met.

5.5 Reconditioned packagings

Reconditioned metal and plastics packagings are the only ones at present defined in the UN recommendations. The department has authorised the use of reconditioned fixed head metal and plastics drums for the purposes of these arrangements under a scheme administered by VCADGO.

5.6 Periodic inspection of IBCs

Modal provisions include requirements for 2½ and 5 year periodic inspections of IBCs. Advice on these requirements and the means of meeting them is contained in the approved requirements.

5.7 The role of VCADGO

The testing and certification processes will require preparation, maintenance and dissemination of operational instructions for test stations. These instructions will include detailed test procedures and other necessary data. In terms of its appointment VCADGO will, on behalf of the department:

• provide test stations with up-to-date instructions covering detailed test procedures and other data necessary for their effective operation
• check test reports and issue new certificates or amend existing ones; call in samples of design types for verification at 5-year intervals
• maintain up-to-date records of all certificates issued
• liaise with certificate holders on amendments thereto and process enquiries relating to the packaging of dangerous goods for transport

VCADGO will establish conditions and may charge fees for each service. VCADGO will consult with industry as appropriate on the operation of its contract.

In the event of a dispute between VCADGO as the certifying body and an applicant for a certificate, an existing holder, or a test station, an appeals procedure exists, details of which are available from DfT.

5.8 Review of these arrangements

The department sponsors meetings of a Packaging Scheme Review Committee to which trade associations with an interest in UN packaging may be represented. This panel reviews matters of principle relating to these arrangements and will resolve major difficulties encountered in interpretation in the UK of the provisions of the UN recommendations. All members of the department’s permanent Working Party on the Transport of Dangerous Goods will be notified of such meetings.