Multilayered Packaging of Hazardous Materials

1. Inquiry

The Homeland Defense and Security Information Analysis Center (HDIAC) received a technical inquiry (TI) asking what technical studies, research, and published work exists concerning the use of containers for the transport and storage of hazardous materials (chemical, biological, radiological [CBR]). The inquirer stated that in the countering weapons of mass destruction (CWMD) community, there are plenty of standard operating procedures (SOPs) about using TeflonTM sample containers and plastic/glass containers with TeflonTM seals and ensuring two to three layers of total packaging around a sample. However, the inquirer has been unable to find the research that supports this, especially research on the advantages of “triple bagging” or having at least three levels of containers around a hazardous sample. Additionally, any research found on the specific type (chemical/polymer) and thickness of plastic bags to use would also be extremely beneficial [1].

2. HDIAC Response

HDIAC conducted a literature search and review of the Defense Technical Information Center (DTIC) Research & Engineering (R&E) Gateway and a review of a dataset that HDIAC has been developing during work on an ongoing core analysis task (CAT) for the Joint Program Manager CBRN Protection (JPM-P) related to contamination mitigation. HDIAC also turned to the Code of Federal Regulations and the Environmental Protection Agency for hazard packaging requirements.

3. Literature Review

Searches of DTIC’s R&E Gateway and HDIAC’s Contamination Mitigation CAT dataset were performed to determine what reports were available. The search terms “Teflon container,” “CBRN packaging,” “chemical agent transport,” and “hazardous storage” returned several thousand results in the R&E Gateway. A manual review of the several hundred documents in the HDIAC Contamination Mitigation dataset was also conducted and did not yield any results pertaining to research on the advantages of multilayered packaging.

3.1. DTIC’s R&E Gateway

Table 1 lists the documents that contained information on package testing of hazardous materials following a review and analysis of the returned results. While none of these documents proved why multilayered packaging is beneficial, the documents did provide supplemental information on regulations to support this practice. Reports listed herein also described different materials used for hazard containment as well as storage and transport container configurations. Some of these reports also discuss regulations on container wall thickness and thickness of padding material but do not directly discuss the reasoning behind such requirements.

Table 1 – Results of R&E Gateway and Contamination Mitigation CAT Literature Searches

Title / Author(s) / Organization		Date Published/ Accession No./ Distribution Statement
Requirements for the Preparation of Sampling and Analysis Plans Author(s): Not available Org: CORPS OF ENGINEERS, WASHINGTON, DC		2001-02-01 ADA402224 A – Approved for Public Release
Safety Author(s): Not available Org: ARMY MATERIEL DEVELOPMENT AND READINESS COMMAND, ALEXANDRIA, VA		1981-08-17 ADA109257 C – US Government Agencies and their Contractors only
Transportable Treatment Systems for Non-Stockpile Chemical Warfare Material. Volume 1. Author(s): Not available Org: OFFICE OF THE PROJECT MANAGER FOR NON-STOCKPILE CHEMICAL MATERIALS, ABERDEEN PROVING GROUND, MD		1999-10-01 CBRNIAC-CB-190493 C – US Government Agencies and their Contractors only
CBRN Decontamination: Multiservice Tactics, Techniques, and Procedures for Chemical, Biological, Radiological, and Nuclear Decontamination Author(s): Lillie, Stanley H., Kelly, John M., Mattis, J. N., Rayburn, Bentley B. Org: ARMY MEDICAL DEPT CENTER AND SCHOOL, FORT SAM, HOUSTON, TX		2006-04-01 ADA523781 A – Approved for Public Release
Navy Transportation Safety Handbook for Ammunition, Explosives and Related Hazardous Materials Author(s): Rinaldi, E. A. Org: NAVAL SEA SYSTEMS COMMAND, WASHINGTON NAVY YARD, USA		1983-06-15 AD1073256 B – US Government Access Only X – Export Controlled
Packaging Digest for Marine Corps, Class V (W) Material. Revision P. Author(s): Niehaus, Frank A., Bedwell, Larry J. Org: NAVAL SURFACE WARFARE CENTER CRANE DIV IN	1998-02-18 ADB236127 B – US Government Access Only

The documents listed in Table 1 vary in their distribution statements and can be provided (as authorized by their distribution code) to holders of a .mil or .gov email address.

3.2. HDIAC Subject Matter Expert (SME) Network Assistance

The HDIAC SME network is one of the Center’s most valuable resources, as it provides a body of knowledge and depth of experience that is far greater than any single person or entity. From time to time, the HDIAC SME network is sought out to assist in answering a technical inquiry. Three SMEs responded to the inquiry, stating that multilayered packaging is common, but none of them could provide information to support this practice.

3.3. Code of Federal Regulations

While no particular studies on the advantages of multilayered packaging of hazardous materials were found during the course of this research, it is clear that this is common practice. In addition to the documents shown in Table 1, HDIAC analysts reviewed Title 49 of the Code of Federal Regulations to determine hazardous material packaging requirements.

The U.S. national standard for shipping HAZMAT can be found in Title 49 of the Code of Federal Regulations (CFR) [2]. Packaging requirements can be found in subparts 173, 178, 179, and 180. After a review of the CFR literature, HDIAC analysts discovered that Category A and Category B infectious substances (biohazards) must be triple packaged. The triple-packaging configuration for each consists of a primary receptacle, a secondary receptacle, and a rigid outer packaging. Detailed descriptions of each layer of packaging can be found in sections 173.196 and 173.199.

Section 178 subpart B details specifications for inside containers and linings. The literature states that primary receptacles must be filled to 98% capacity in order to combat vibrational movements during transport. Inner receptacles containing liquids must have an adequate quantity of absorbent material to be able to absorb all liquids in the primary containers. The outer packaging for primary containers containing liquids or solids must have additional means of containing the substance in order to prevent leakage, such as a plastic bag or leak-proof liner.

While the review of the Code of Regulations did not explain the basis for two or three layers of total packaging, it did hint at some advantages – namely, combatting vibrational movements, leak prevention, and safety.

3.4. Environmental Protection Agency

After detailing the biohazard packaging requirements mentioned in the CFR, HDIAC analysts turned their attention to locating additional packaging and storage studies pertaining to chemical hazards. The U.S. Environmental Protection Agency (EPA) is responsible for the Environmental Sampling and Analytical Methods (ESAM) Program [3]. ESAM is composed of information supporting field and laboratory efforts for environmental protection. It is possible to query the ESAM Program’s Chemical Sample Collection Information for a particular (or multiple) substance(s). The system returns methods, sample sizes, sample containers, holding times, preservations, packaging requirements, and shipping labels for each desired substance. After assessing the sample containers and packaging requirements for common chemical warfare agents (e.g., VX, GA, Lewisite), HDIAC analysts discovered that packaging requirements for many CWAs were similar, if not exactly the same. Solid, liquid, and “wiped” chemical specimens required the packaging listed in Table 2.

Table 2 – General Packaging Requirements for Solid, Liquid, and Wiped Chemical Hazards [3]

Packaging Requirements:

Wipe outside of container clean using a damp, then dry cloth. Wrap container with bubble wrap. Place in gallon plastic (polypropylene or polyethylene) bag with zipper lock and durability to resist punctures, then into a metal can before placing in cooler. Pack sample transport containers outside the contaminated area. Samples must be packed in a manner that protects the integrity of the samples and provides temperature conditions required for sample preservation. Samples should be surrounded by shock- and water-absorbent packing materials or ice (if required for preservation) and shipped in a cooler to ensure sample temperatures do not exceed preservation requirements. If the target analytes are unknown, samples should be maintained at ≤6°C but above freezing. Ice should be placed in separate plastic bags, or cold packs should be used to avoid leakage and the bags placed around, among, and on top of the sample containers.

Gaseous specimens of CWA materials have different packaging requirements than those in Table 2. These general requirements (shown in Table 3) are similar, despite the chemical type being packaged.

Table 3 – General Requirements for Packaging Vaporous Chemical Hazards [3]

Packaging Requirements:

Place filter in protective covering. Place protected filter in double plastic bags and wrap with bubble wrap. Pack sample transport containers outside the contaminated area. Samples must be packed in a manner that protects the integrity of the samples and provides temperature conditions required for sample preservation. Samples should be surrounded by shock- and water-absorbent packing materials or ice (if required for preservation) and shipped in a cooler to ensure sample temperatures do not exceed preservation requirements. If the target analytes are unknown, samples should be maintained at ≤6°C but above freezing. Ice should be placed in separate plastic bags, or cold packs should be used to avoid leakage and the bags placed around, among, and on top of the sample containers.

This ESAM Program, like other sources sought by HDIAC, did not provide why multilayered packaging is required; however, it did provide some insight into the requirement. It should be noted that both of these requirements require several layers of packaging, including bubble wrap used around the container. It can be inferred that this is done to ensure the integrity of the samples by absorbing shock and limiting vibrational movements. The conclusion can also be drawn that multilayered packaging lessens the risk of leakage, providing enhanced safety to personnel as well as the environment.

4. Conclusions

After reviewing all information gathered, HDIAC could not find any reports investigating the benefits or purpose behind multilayer packaging of hazardous materials. The information gathered, however, supports the accepted practices and procedures by both providing enhanced safety protocols for individual hazardous substances as well as complying with federal regulations. Almost every document reviewed mentioned at least two layers of packaging for a substance, with most reports suggesting even more. It can be inferred that the more a substance is contained, the less likely the threat is to escape. This enhances the safety of personnel, equipment, and the environment, which is even more pertinent when the substance is shipped or handled through multiple agencies or organizations. While each layer of packaging can be assumed to provide additional safety measures, it is understood that over-packing can increase costs and man-hours. Therefore, organizations must determine if an increase in packaging past that of what is required by regulation is worth the increase in expense. It can also be inferred that this is why there is an abundance of differing standard operation procedures pertaining to different industries and sectors, as they are tailored to the substances handled as well as the facility from which they originate.

Although it exceeded the scope of the free technical inquiry service offered by DTIC, it may be possible to ascertain if there is more evidence that supports the multilayered packaging requirements prescribed by the CFR by analyzing the documents referenced within and which provide the basis for the CFR. Should such analysis be required, it would be possible for the HDIAC to undertake this research and to provide such a report via a customer-funded core analysis task. More information on this process is available at https://www.hdiac.org/services/core-analysis-task-cat-program/ or on DTIC’s website at https://dodiac.dtic.mil/services/#BCO_TO.