“Packaging” is defined in the dangerous goods transport regulations as follows:
A receptacle, any other component or material that performs the function of containing the materials placed in it and that meets the following conditions:
- designed to contain a net mass not exceeding 400 kg,
- designed for a capacity not exceeding 450 L,
- not intended for the carriage of many gases,
- not intended for the carriage of many infectious substances,
- not intended for the carriage of many radioactive materials,
- not falling within the scope of the Intermediate Bulk Containers described in Article 6.5 of the UN Recommendations.
Packagings within this scope receive a suitable code according to the table in ADR Chapter 6.1.2.7, based on an assessment of their raw materials, shapes and additional construction features. Classification is made in the same way in other modes of transport, but some modes of transport may not allow certain types of packaging to be carried.
Once the type of packaging has been determined, how robust the packaging needs to be for the substances it is intended to carry, in other words at what levels the performance tests will be applied, is determined by consulting the relevant part of the regulation. The most important criterion here is the Packing Group, which indicates the danger level of the substance. Packing groups are shown in Roman numerals and there are 3 of them: I (high danger), II (medium danger) and III (low danger). More demanding test levels are applied to packagings intended to carry substances with a high danger level. For example, in the drop test a packaging that will carry a PG I substance is dropped from 1.2 m, while a packaging that will carry a PG III substance is dropped from 0.8 m. The tests to be applied to packaging types and the related levels are given both in the dangerous goods transport regulations and in the TS EN ISO 16104 and TS EN ISO 16106 standards. In general, the tests that can be applied to packagings are the drop test, leakproofness test, internal pressure (hydraulic) test, stacking test, chemical compatibility test, permeability test and determination of water absorption by the Cobb method.
A company wishing to obtain approval for a packaging design must first register with TSE's system if it is not already registered. The application can then be made. Registration and applications are made at http://belge.tse.org.tr/index.aspx (opens in a new tab) (also accessible from http://tmt.tse.org.tr/). The documents requested from companies during the application consist of administrative documents such as the Quality Management System Certificate, Signature Circular, Trademark Registration Certificate and Chamber Registration, and technical documents such as Technical Drawings, Tests Applied at the Company, Quality Control Plans, and Raw Material and Equipment Certificates. After the company submits its application, the application reaches the Technical Manager through the system and is assigned to an expert. The expert first checks the documents uploaded to the system and has any deficiencies and errors corrected by communicating them to the company representative. Once all deficiencies have been remedied, a company visit is made for the Production and Production Site Conformity Audit and for Sampling. The audit, based on TS EN ISO 16106, examines whether the company is able to produce the packaging in question at a quality suitable for the carriage of dangerous goods. By reviewing this standard before applying, companies can identify and correct their deficiencies and thus shorten the design approval process. After the deficiencies found in the Production and Production Site Conformity Audit have been remedied and the test results of the samples are received, if the test report is positive a Design Approval Certificate with a detailed scope annex is issued to the company. With this certificate, valid for 5 years, the company obtains the right to print the UN marking specified in the scope on its products, and international carriage of dangerous goods can then be carried out with these products within the scope.
You can find all information on the Packaging Design Approval process (a knowledge base with detailed information on the processes, explanatory videos on the online application process, contact details of experts you can ask questions, etc.) at http://tmt.tse.org.tr/ (opens in a new tab).
Design Approval Process for IBCs and Large Packagings
Intermediate bulk containers (IBCs) are defined as rigid or flexible portable packagings designed for mechanical handling, and Large packagings as outer packagings containing articles or inner packagings and designed for mechanical handling. For IBCs and Large Packagings, which may be made of various rigid and flexible materials including metal, plastic, composite, textile, paper, natural wood, plywood and reconstituted wood, the capacity limits are:
- IBCs carrying solids and liquids of packing groups II and III: max. 3 m3
- Flexible, rigid plastic, composite, fibreboard or wooden IBCs used to carry solids of packing group I: max. 1.5 m3
- Metal IBCs used to carry solids of packing group I: max. 3 m3
- IBCs carrying Class 7 radioactive material: max. 3 m3
- Large Packagings: more than 400 kg net mass or 450 litres capacity but less than 3 m3.
An IBC or Large Packaging designed to carry dangerous goods must have properties meeting the criteria of the relevant mode of transport (IMDG CODE, ICAO/IATA, ADR, RID) and must successfully pass the relevant tests according to its performance level.
As a result of the review of the application made to TSE online, if suitable, the Production and Production Site Conformity Audit and the prototype tests are carried out. If the prototype tests are passed successfully, a Design Approval certificate is issued and a UN code is assigned to the type concerned. In addition, metal, rigid plastic and composite intermediate bulk containers with a plastic inner receptacle are subject to an initial inspection before being put into service and, after being put into service, to an intermediate inspection every 2.5 years and a periodic inspection every 5 years.
Issue of Documents and the Security Label
Following the company's application, once the Review Board has completed the inspections and tests, the files prepared together with the resulting reports are submitted to the certification committee. After the Certification Committee has reviewed the reports submitted, the files are delivered to the Administrative Office in line with the decisions taken.
These files are checked by the administrative office and the printing of the documents is completed. After the documents are signed by the administrative manager, a security label is affixed to the original of each document. Once the company has completed its financial procedures, the documents are sent to the company representative by courier and the archiving procedures are completed.
