Boxmaker: 4G Boxes and the HMR

Thursday, February 8, 2024 | 2:00-3:30pm ET  

The Hazardous Materials Regulations (HMR) apportion responsibilities to “persons” who perform “functions” as applicable in the HMR. The HMR states that:

§171.2 GENERAL REQUIREMENTS

“(a) Each person who performs a function covered by this subchapter must perform that function in accordance with this subchapter.”

In addition, we see that there are specific functions under the HMR, the responsibility for which, are apportioned to any party that performs a regulated function for a “packaging manufacturer.”

§178.2 Applicability and responsibility.

“…(2) A manufacturer of a packaging subject to the requirements of this part is primarily responsible for compliance with the requirements of this part. However, any person who performs a function prescribed in this part shall perform that function in accordance with this part.”

These requirements could affect a box converter, even if they are NOT the “Packaging manufacturer” as identified in the regulations.

Overview

This webinar presents an analysis of the requirements of the HMR with respect to “packaging manufacturers” as defined in the regulations; and any parties, such as a box maker (fabricator) that performs regulated functions on behalf of their "packaging manufacturer" customers.

Learning Objectives

The requirements of 49 CFR Subparts L and M of Part 178 as applicable to box converters.

• Identification of the “Packaging Manufacturer” for the purpose of regulations.
• Definition of a “Different packaging” for the purposes of the regulations as applicable to fiberboard boxes. Particularly focused on the requirements for manufacturing a 4G packaging from a previously manufactured packaging identified in a Design Qualification test report.
• Specific requirements for hazardous materials packaging [fiberboard (4G) packaging] applicable to box makers and packaging manufacturers.
• Testing requirements for UN specification packagings
• Record retention
• Quality considerations that can influence regulatory compliance

Who Should Attend?

• Hazmat employees who perform specific functions related to design, specification, and conversion of boxes for hazardous materials
• Sales and Marketing Professionals
• Designers
• Quality Control Personnel
• Customer Service Representatives

Why Should I Attend?

It is important for a box maker to keep clear lines of responsibility with customers in the production of UN Standard hazardous materials packaging to prevent being the cause of a violation; even when it is the customer who is identified as the "packaging manufacturer" under the regulations. In the conversion of fiberboard boxes for use in the transportation of hazardous materials, there are structural, design, and quality considerations that need to be incorporated into the processes of converting and selling these regulated boxes; even for box converters who are not identified as the “manufacturer” of a packaging for the purposes of the HMR. Knowledge of the specific regulatory requirements for hazardous materials packaging is the best first step to a comprehensive and effective compliance program. Seemingly minor mistakes or quality lapses can lead to enforcement actions and damaged customer relationships, with concomitant product claims. Prevention of these issues before boxes are made and shipped is the best solution from a business and regulatory standpoint.

Registration
This webinar is available for FREE to AICC Members in good standing.

Meet Your Instructor

Lonnie Jaycox CPP, CDGP is an independent packaging engineer, consultant, and trainer in the implementation of compliance systems and packaging programs for regulated materials including hazardous materials (dangerous goods). Jaycox has spent over 30 years designing, testing, manufacturing, and implementing packaging programs for the transportation of Hazardous Materials. Jaycox is active in industry and related organizations including AICC.

Effective September 1, 2023 - AICC will be offering LIVE webinars throughout the year. Webinars will be offered free to all members who register. If you are registered and don’t attend the live webinar, you will only get access to the recording if your company is a member of the All Access Pass. If your company is not an All Access Pass participant, then the recording will be available for a fee on AICC NOW.