 Edwin E. Olds
The story behind the routine shipments of materials to chemists all over the world is anything but routine. Packaging requirements adopted in 1990 with the passage of Hazardous Materials Docket 181 (HM181) revised the rules - and increased the costs - for the entire chemical industry, making manufacturers large and small scramble to meet them. Since then, a continuous stream of changes, updates, and sometimes inconsistent requirements has completely revamped the business of chemical distribution. Before 1990, chemical manufacturers generally could purchase boxes and shipping crates from nearly any box company, most of which followed standards set by the US Department of Transportation (DOT). From 1990 on, packaging requirements have been established and enforced by a host of entities, including DOT, which oversees Title 49 of the Code of Federal Regulations (49CFR), the main body of US federal regulations dealing with transportation issues, of which HM181 is a component. Private organizations, such as the International Air Transport Association and the International Civil Aviation Organization, impose air standards, and the International Maritime Organization governs shipments by sea. Nearly every country across the globe sets its own packaging requirements. In addition, nearly every freight carrier, from Federal Express (FedEx) to United Parcel Service (UPS), has now developed company-specific codes and rules for packaging and shipping. To meet these new requirements, chemical companies need to constantly improve their operations, provide up-to-date training, and develop new partnerships to survive and grow.
NEW PACKAGING
The type of tests selected depends on how a package will be used and what it will carry. For example, boxes and packing contents often undergo drop or stack tests. Air shipments may be subject to pressure checks that chart how pressure changes affect interior containers.
 Packages are classed into three groups based on the hazard rating of the contents: X signifying the most severe, Y denoting medium severity, and Z indicating the least hazardous. Accordingly, packaging also is classified by its ability to protect hazardous products: PG1 for the most severe, PG2 for materials in the middle range, and PG3 for the least hazardous. Many criteria enter into the final prescribed formula for a package. That's why the creation of these packages now is based on factors such as product weight, container weight, and the types of materials to be shipped.
INDUSTRY RESPONSE
Large companies responded by establishing their own in-house package-testing laboratories, hiring full-time trainers to work with line employees, and, in some cases, manufacturing their own packaging. Many mid-sized companies, however, found that their policies for customer responsiveness and their size precluded following similar tactics. Although these companies intended to maintain or expand their range of products, they simply could not support full-time trainers, in-house packaging operations, or a testing laboratory. More innovative and cost-efficient solutions were required. For example, shipping, receiving, and traffic personnel can attend outside training sessions. A variety of companies, including GFI (Branson, MO), the International Compliance Center (Niagara Falls, NY), and Hazardous Materials Compliance (Leesburg, FL), offer training programs. These providers are particularly valuable for converting theoretical information into practical use for daily operations. Employees can also stay current with specific freight company rules by attending training sessions sponsored by freight shippers. This joint participation results in a bonus because it helps companies continually shape and refine their relationships with these shipping partners. Sessions coordinated by DOT's Research and Special Programs Administration can be very valuable because presenters include regulatory agency personnel such as staff from DOT, the US Federal Aviation Administration (FAA), and the US Coast Guard. At a time when regulations can change drastically over a three-month period, agency personnel may be the best source for the latest updates. These sessions also afford an opportunity to discuss with regulators impractical, inconsistent, or unintended regulatory impacts from the perspective of those who depend on planes, trains, trucks, and boats for shipping. Examples of conversations that GFS Chemicals representatives have had are:
PARTNERING STRATEGIES However, given the complexities of shipping standards, a company may need to supplement this expertise with assistance from other sources. One way is to establish partnerships with outside freight-forwarding companies. Many of these shipping experts have crafted their own agreements with certain foreign countries and can import chemicals more quickly and efficiently than any manufacturer. Belgium, for example, has strict rules when it comes to exporting or importing goods - unless you have a freight forwarder with an Antwerp connection. These firms are invaluable for double-checking your packaging choices. They, too, stay abreast of land, air, and sea regulations and are expert at examining the packaging demands presented at each step of a product's journey. Just as mid-size companies often cannot support in-house trainers, they generally have to reject the idea of in-house package testing labs or packaging arms. The costs of such additions are high for several reasons, including the requirement that even proven performance packaging must be re-tested every two years, whether anything in the package has changed or not. GFS Chemicals, like many other mid-sized companies, seeks to address these issues through strategic partnerships with suppliers of performance-tested packaging. The company's alliance with one supplier cut costs and created a specific source for specialized individual and overpack shipping containers for 2.5- and 4.0-liter bottles. GFS shared its industry knowledge to guide the packager to reach its shipping objectives. In turn, the supplier now has a product to sell within a larger marketplace. Another benefit of this alliance is the ability to tap the expertise of packaging personnel. Nearly every packaging company has an in-house "guru" who can prove to be a tremendous resource. GFS has learned that certain shipping needs can no longer be met because of weight restrictions. But, before throwing in the towel, GFS connects with these experts, who often find alternative solutions. Partnering promotes the availability and affordability of performance-tested packaging customs to meet the needs of small and mid-sized chemical companies.
THE COST OF CHANGE
One can attribute these rising expenses to lab testing, packaging materials, and higher freight fees. Initial cost increases and time delays stemmed from a scarcity of testing labs. Until recently, so few packaging labs existed that the turn-around time for test results stretched from six to ten months. When attempting to stay close to customers and quickly respond to their needs, time is at a premium. And, as can be expected, the fewer labs, the higher the costs for testing. The additional testing steps created by 49CFR also mean that higher quality materials are used in packaging - another cost increase. The old DOT box typically was cardboard, with cardboard dividers between bottles. Now, the gauge of cardboard used for the box is heavier, the inserts are styrofoam, sealed plastic bags surround each bottle, and sometimes metal cans must be used to package glass bottles. Stronger regulations also drove up freight fees and narrowed carrier options. FedEx, for example, now assesses a flat $40 fee on any shipment classified as "hazardous," and UPS charges a $12 fee. Worse, some carriers refuse to handle any hazardous materials at all. Again, companies must work to resolve these challenges by forming alliances with key freight carriers.
Today's emphasis on safe handling and transportation of chemical products is laudable and, to some extent, long overdue. Most of the initial regulations generated in this area took root in the 1970s but remained only concepts until the first half of this decade. Continuous delays in rule implementation actually may have lulled some in the industry into a false sense of security. Further, since no real demand was created for testing labs or specialty packagers, these support industries were slow to evolve, making it even more challenging for manufacturers to quickly adapt to regulatory standards. Most manufacturers, regardless of size, place great emphasis on shipping and handling safety. Such awareness has extended not just to the outgoing freight dock, but also to incoming supplies, as companies understand their own liability for accepting improperly packaged raw materials. However, as is often the case with new regulatory efforts, some reevaluation of the efficacy and inconsistency of various rule-making agencies is needed. Some believe that not all performance-oriented packaging actually is superior to previous packages. But, with the biannual testing requirement, the cost of reintroducing such packages is prohibitive. At the same time, manufacturers must apply their ingenuity to reengineering packaging and distribution systems that promote safety, continue giving customers flexibility and choices, and are as cost-efficient as possible.
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