Dangerous Goods PackagingThis page was last updated on 5th February 2020
Packaging Revalidation at 5 Years
In most cases, packaging which is used for the carriage of dangerous goods needs to be UN certified. To achieve UN certification, samples of the packaging together with any inner packaging (cans, bottles etc.) which they are to contain must be subjected to a series of tests, conducted by an approved laboratory. This is known as type approval or design type testing. A design type that passes the tests is issued with a performance certificate and a unique UN approval mark, which can be applied to packaging that conforms to the same specification as the tested type.
The regulations require UN packaging to be manufactured under a quality system which satisfies the competent authority. For packaging approved by the UK (GB marked), a quality system meeting the requirements of ISO 9001 is acceptable. However, to ensure compliance with the approved specification, independent checks are periodically undertaken on specimens of each design-type.
At least once every five years, the certification of each UN approved packaging type must be revalidated. This involves a physical check of samples of the packaging and any associated inner packaging(s), to confirm their specification. The date by which revalidation must be complete is shown at the foot of all current UK certificates. If a certificate issued by the UK bears no ‘revalidation due’ date, the copy in question is out of date and will have been superseded by a later issue. In the event that the current certificate has been misplaced, the certificate holder may obtain a replacement from VCA for a small fee.
Approximately nine months before revalidation is due, VCA will send a reminder to the last recorded contact at the certificate holder’s address. Reminders are sent simply as a courtesy; the certificate holder alone is responsible for ensuring that their packaging is sent for revalidation in good time and VCA shall not be liable if for any reason a reminder is delayed, misdirected or fails to arrive.
The revalidation process
To revalidate a certificate, the certificate holder must submit a recently manufactured sample, including inner packaging(s) where applicable, to an appointed test station for checking. A list of test stations is available on the VCA website. The fees for conducting the revalidation work are a matter for agreement between the test station and the certificate holder. VCA does not set standard fees.
The test station will make measurements and perform checks on the packaging, similar to those conducted as part of the original test program, and will compile a short report which will form the basis of an application to revalidate the UN certificate. The test station will, on behalf of the certificate holder, submit the application to VCA. who will review it in conjunction with the original test records. If the specification of the packaging accords with the information held on file for the design-type, VCA will reissue the certificate for a further 5 years before revalidation is next due.
Certificates are often amended during their lifetime to accommodate changes in specification or to broaden scope. For example, the addition of an alternative closure to a drum or a new inner to a combination packaging would result in a certificate amendment. In many cases a specification check will be required as part of an amendment and when this is done the resulting certificate may be reissued for a further 5 years before revalidation is next due. In all other cases, the ‘revalidation due’ date on a reissued certificate will not be amended.
Refusal to revalidate
Revalidation may be refused for a number of reasons including, but not limited to:
- Failure to perform the required checks on a recently manufactured packaging
- Significant differences in specification between the original packaging design type and the sample(s) submitted for revalidation
- Unpaid annual or other fee
In all cases VCA will advise the certificate holder of the reason for refusal and whenever possible, will provide guidance on the action which must be taken before the application can be reconsidered.
Suspension of certificate
If a packaging approval has not been revalidated by the due date, it will immediately lapse into suspension. The Packaging Certificate will cease to be valid authorisation to apply the associated UN mark to the packaging and no further packaging of that type may be produced or UN marked. Notification of the suspension will be sent to the certificate holder at their last recorded address. The certificate will remain in suspension until the packaging has been satisfactory revalidated.
In most cases, packaging which was manufactured and marked before the certificate was suspended may be used until stocks are exhausted, even if the certificate has not been revalidated. However, if revalidation was refused because significant differences were found between the packaging that was submitted for the revalidation check and the original approved design-type, none of that packaging may be used. All stocks of out-of-specification packaging must be withdrawn and destroyed, or at the very least their UN markings must be permanently obliterated. Certificate holders are reminded that the supply or use of ineligible or incorrectly marked packaging for the carriage of dangerous goods constitutes an offence under CDG 2009 regulations
Revalidation and annual fees
Annual fees are payable for maintaining a certificate on the register, irrespective of whether it is current or is in suspension. Providing annual fees are not in arrears, no charge will be made for reissuing a certificate following the successful revalidation of the associated packaging. However if revalidation is refused because the packaging was out of specification, a fee may be charged for each subsequent application to revalidate that certificate. When revalidation coincides with an application for amendment of the certificate, a standard amendment fee will be payable.
The unique GB certificate number which is allocated to an approved package design type will remain with it for life (i.e. from one revalidation to the next) providing the package specification does not alter. The certificate holder must ensure the correct code for the year of manufacture is shown in the mark applied to the packaging and that may then be checked against the list of approvals on the VCA website to confirm it was produced during a period of validity. Misapplication of a year code with intent to deceive is likely to constitute fraud.
Additional intermediate quality assurance checks
As part of the overall quality assurance program, VCA may require a certificate holder to submit specimens of an approved packaging for checking at any time during the life of the certificate. If the check is completed satisfactorily, the certificate will be reissued for a further five years before revalidation is next due.