UN Testing – Can the same code be used for different suppliers?

Dana asks,

I have a few questions for you regarding UN testing. We have a customer who requires testing for their HazMat packaging. A few questions arose when we met with them recently. If you could offer your expert answer on the following, I would greatly appreciate it.

For one item they have 2 different bottle suppliers. If they include one bottle manufacturer’s specification, can they use a different manufacturer who follows the same specification? Or does the test need to be run for each different situation? If the test needs to be run for each different situation, how does the code on the box work? Can you have more than one code per box or would that one code be able to cover the 2 different bottle manufacturers?

If the customer uses 2 different caps on the same bottle, must each situation go through the test? Again, same question applies to the code on the box. Can they use the same box with 2 different cap situations?

The customer is using various different labels on the bottle. I believe this is okay as the labels vary slightly in thickness, but I do not recall seeing a material data sheet for the label when the prior testing was completed.

The customer uses different collars on the bottles. Does the collar need to be included in the testing and same questions apply here as the above cap and bottle situations?

I reached out to my associate Steve Brion at Ten-E Packaging Services for help with this question. Steve’s expert answers are below. — Ralph

“Yes, you can test one bottle manufacturer and use other bottle manufacturers as long as the product they supply follows the same specifications, or falls under Selective Testing Variation #1 in Title 49, CFR.

If your customers uses different types of closures on the bottles, then each closure variable combination must be tested and rate. Collars would also be treated the same as caps and closures. Each collar variable combination would need to be tested as a change in cap or collar design in essence changes the structure and/or specification of the container.

I haven’t dealt much with labels, but unless the label is structurally part of the bottle it shouldn’t make any difference for testing purposes.”

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