Hazmat Paperwork Lifecycle

Tim asks,

How long do we need to keep our paperwork for boxes where we print the UN hazmat logo’s on?

I reached out to Lonnie Jaycox (lonnie@jaycoxconsulting.com) for some help on this topic. Below is Lonnie’s reply. Thank you Lonnie for your assistance.

— Ralph

If the Hazmat logo is the certification mark for specification packaging; it depends on the paperwork “who” (which person) the box plant is listed in the regulations.

If the box plant is both the fabricator of the box and the “manufacturer” of the packaging under 49 CFR (It is their name or symbol that appears in the certification string.). Then they will need to keep design qualification test reports for the period specified in 49 CFR 178.601(I) [see below]:

  • Record retention: Following each Design Qualification (DQ) test and each periodic retest on a packaging, a test report must be prepared. The test report must be maintained at each location where the packaging is manufactured, certified, and a design qualification test or periodic retest is conducted as follows:

 

Responsible Party Duration
Person manufacturing the packaging As long as manufactured and two years thereafter.
Person performing design testing Design test maintained for a single or composite packaging for six years after the test is successfully performed and for a combination packaging or packaging intended for infectious substances for seven years after the test is successfully performed.
Person performing periodic retesting

Performance test maintained for a single or composite packaging for one year after the test is successfully performed and for a combination packaging or packaging intended for infectious substances for two years after the test is successfully performed.

If the box plant is a fabricator (not the manufacturer), then is no need for them to retain a copy of the DQ report at all, since there is no requirement that they have it to begin with. In that case, the manufacturer simply gives the construction specification to the box plant to manufacture. However, because the person responsible for the specification and performance of the packaging is required to maintain records for two years after a packaging is no longer manufactured, I would recommend that the production records for boxes marked with a UN specification marking should be retained for two years. That way if there is any question as to the construction of the packaging, the fabricator could demonstrate from their records that the manufacturer’s specifications were followed.

If the “paperwork” mentioned above is not associated with the UN specification marking, I would need some clarification of what UN marking is being discussed.

 

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One Response to “Hazmat Paperwork Lifecycle”

  1. Pat Haddon Says:

    So if the fabricator (us) is not the manufacturer and tester of the components, should we let the manufacturer put a bmc on the bottom of the box?

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