Packaging Waste Reduction

Standards: Rule 180

Need a new direction for your transport packaging?
Do a 180!

By Alfred H. McKinlay, P.E.

In case you haven't heard, there is a new "game in town." No longer are minimum material/design specifications the only way for shippers to package their products for common-carrier transportation (by LTL less-than-truckload shipments anyway). Now there is an optional or alternate method open to all shippers of non-hazardous goods.

In November 1994, the National Classification Committee (NCC) approved a new Rule for the National Motor Freight Classification (NMFC) and gave it the number 180. Effective January 1995, the new Performance Test Packaging Rule made it possible to use any material or design for transport packaging if it can pass a set of performance tests spelled out in detail in the new regulation. All kinds of containers are included, except drums, pails, and bags due to their difference in accepted test procedures. The new rule applies only to LTL common carrier shipments, although other motor carriers, such as full truckload contract carriers, could reference it as well if they so choose.

The benefits to carriers and users of Rule 180, as presented by Al McKinlay speaking for the IoPP committee at the NCC hearing, are:

• "Adequate protection" defined--This term is used frequently throughout packaging rules in the NMFC, without definition.   It is a source of considerable disagreement between carriers and shippers when damage is incurred and claims disputed.  Now we have the test procedures of Rule 180 which define how much protection is adequate.
• Reduction in damage claims--The container Rules of the NMFC, such as 222 for corrugated boxes, do not define if or how much interior packaging is needed. With Rule 180, a standard definition is given for required performance of the whole transport package in LTL shipping, and results of an extensive testing program show the definition tracks good performance.
• More creativity in transport packaging design--In general, no matter whether it's packaging or building blocks or electronics or whatever, performance specifications have led to more creative solutions and products than ever possible with more rigid material/design specifications. Both our federal government and the GATT world trade agreement endorse the concept.
• Source reduction of packaging materials--Tied in with the creativity benefit is the greater opportunity to explore alternatives which may lead to reduction of packaging materials required to do the job of total performance in safe and economical distribution of goods.
• Improved customer satisfaction--The current trend to greater awareness of customer satisfaction in total quality improvement will find a friend in Rule 180 and its use to bring down damage complaints.
• Reduce cycle time for package design and certification--A roadblock for many potentially good ideas is the time and expense to prove their viability as an adequate transport package.  Rule 180 reduces both time and cost dramatically as one successful day in the lab can replace most of the trials.  Gone are the requirements for 6 to 12 months of expensive trial shipments, although some are still a good idea to provide final verification of a new concept.
• Reduction in recordkeeping--Those shippers and carriers show now do extensive test shipments under Item 689, as required for exceptions or new numbered packages, will really appreciate the elimination of the tremendous recordkeeping those test shipments require.

The opening paragraph of Rule 180 makes it clear that the Rule is an alternative to existing Rules, therefore no one is forced to use it. But those who will most probably use it are shippers who are looking for improved packaging (less damage), for a clear definition of performance requirements for packaging of high value products, or for replacing the lengthy test shipment protocol required for any changes or additions to numbered packages (such as furniture, large appliance, TV industries, and some others are required to use). The new Rule even includes a performance requirement for palletized loads, something motor carriers really like since such loads many times fall apart while in their care.

The performance requirements are a two part test sequence: first a compression/vibration test representing hazards of over-the-road travel; and second, an impact/handling test representing hazards in terminals. The tests are based on ASTM methods with a strong, although not identical, flavor of the ASTM Performance Test Practice D4169. All details of the test procedures, in fact the entire Rule as proposed to the NCC, were hammered out in two years of intense work by a technical committee of the Institute of Packaging Professionals (IoPP).

A variety of test method and equipment options are included, making it possible for most transport packaging testing laboratories to conduct the required methods. Since a number of Canadian motor carriers are participants in the NMFC, the test methods are also given in metric terms. The rule states that any competent laboratory may conduct the tests, that a test report must be on file, and that the shipping unit (transport package or palletized load) must bear the new triangular certification mark.  The organization certifying the shipping unit may be the shipper, the International Safe Transit Association (ISTA), or any other third party, and must have its name and address shown directly above the certification marking.

Al McKinlay spearheaded a group of 75 transport packaging professionals assembled by IoPP to work out this performance-based rule. McKinlay, internationally known consultant and all-around packaging guru, literally wrote the book on transport packaging.  For information about his services and experience, visit his Web site at www.transport-packaging.com

McKinlay's book, Transport Packaging, is geared toward ALL packaging professionals whose job responsibilities encompass transportation and distribution packaging. For more information about its contents and how to order, see the IoPP Bookstore.

The identification of individuals, companies, and products in this document does not constitute endorsement by the Integrated Waste Management Board and is provided for informational purposes only.

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