What is covered by the packaging requirements?
The Hazardous Substances (Packaging) Regulations follow the packaging requirements of the UN system for transport of dangerous goods.
A 'package' is defined as the packaging plus its contents. 'Packaging' includes:
- the container holding a substance
- any other components necessary for the container to perform its containment function. For example the combination of an outer and in layer packaging system.
What is excluded from the packaging requirements?
The following are not subject to the Packaging Regulations:
- containers permanently fixed in one place, including any container permanently fixed to a vehicle
- large transportable containers such as intermediate bulk containers (IBCs) and portable tanks. These are covered by the Hazardous Substances (Tank Wagons and Transportable Containers) Regulations 2004
- containers for holding compressed gases or aerosols. These are covered by the Hazardous Substances and (Compressed Gasses) Regulations 2004
- fuel systems, electrical systems or control systems of a vehicle, aircraft or ship
- fuel gas distribution systems, installations or appliances that are subject to controls specified in regulations made under the Gas Act 1992.
Why is packaging important?
Hazardous substances need to be packaged in containers strong enough to prevent potentially hazardous incidents. There are three requirements that need to be considered in determining the appropriateness of packaging for any hazardous substance. These are:
- The general requirements, relating to 'fit for purpose'.
Every package used to contain hazardous substances must:- Be able to retain its contents in non-emergency situations
- Be compatible with its contents so that packaging performance is not degraded by the substance (eg corrosive substances will degrade inappropriate packaging)
- Be suitable for the properties and state of the substance
- Not be marked as belonging to a packing group if it does not meet the requirements of that packing group.
- Not be re-used with other substances if they are incompatible with the previous substance, unless all traces of the previous substance have been removed.
- The United Nation's Packing Group requirements relating to hazardous properties.
- HSNO packaging requirements are aligned with international standards, notably the United Nation's Transport of Dangerous Goods Model Regulations where three 'Packing Groups' are identified; PG 1, PG 11 and PG 111:
- UN PG 1 is equivalent to Schedule 1 of Packaging Regulations.
- UN PG II is equivalent to Schedule 2
- UN PG 111 is equivalent to Schedule 3.
- A fourth packaging standard (Schedule 4) may be used for less hazardous substances or when hazardous substances are packaged in smaller quantities. To use Schedule 4 packaging, certain qualifying criteria (contained in Schedule 5) relating to hazard classification, quantity and physical state must be met.
- Each Packing Group has a specific minimum level of performance set out in standardised tests that involve a package's resistance to dropping, stacking, pressurisation (internal), and leaking.
- HSNO packaging requirements are aligned with international standards, notably the United Nation's Transport of Dangerous Goods Model Regulations where three 'Packing Groups' are identified; PG 1, PG 11 and PG 111:
- Additional packaging requirements.
- Some hazard classifications have additional packaging requirements. For example child resistant closures are required for packages holding less than 2.5kg of substances with certain toxic or corrosive hazard.
How to find out the packaging requirements for a substance?
Find out the hazard classification of the substance. This is the key to determining which packing group is required. The hazard classification will determine both the packing group required and any additional packaging requirements relating to its hazardous properties.
Where a substance has two or more hazard classifications, as many will, the most stringent (lowest number) of the packing groups triggered is the one you must met.
Packaging must take into account all requirements imposed by each of the substances' hazard classifications.
You also need to look at the ERMA New Zealand register on our website for the final controls applied for approved hazardous substances.
When do products need to meet the new packaging requirements?
Providing the product complies with the current packing requirements, his depends on when the substance you intend to package was transferred . :
Who is responsible for packaging?
Any manufacturer or importer packing or repacking hazardous substances will need to ensure that the packaging is designed and constructed specifically for use with that particular hazardous substance.
For most businesses, the practical effect of packaging is limited to repackaging hazardous substances and re-using containers on site as the container the hazardous substances has been supplied in should already meet the packaging requirements.
The same rules apply to repackaging as they do to the original packing!