Writing Closure Instructions(3) 2011
- 15. 178.2(c) CONTINUED Notify in writing each person to whom that packaging is transferred Of all requirements in this part not met at the time of transfer, and (ii) With information specifying the type(s) and dimensions of the closures, including gaskets and any other components needed to ensure that the packaging is capable of successfully passing the applicable performance tests.
- 16. 178.2(C) CONTINUED This information must include any procedures to be followed, including closure instructions for inner packagings and receptacles, to effectively assemble and close the packaging for the purpose of preventing leakage in transportation. For packagings sold or represented as being in conformance with the requirements of this subchapter applicable to transportation by aircraft, this information must include relevant guidance to ensure that the packaging, as prepared for transportation, will withstand the pressure differential requirements in 173.27 of this subchapter.
- 17. (l) Record retention . Following each design qualification test and each periodic retest on a packaging, a test report must be prepared. The test report must be maintained at each location where the packaging is manufactured and each location where the design qualification tests are conducted, for as long as the packaging is produced and for at least two years thereafter, and at each location where the periodic retests are conducted until such tests are successfully performed again and a new test report produced.
- 18. In addition , a copy of the test report must be maintained by a person certifying compliance with this part. The test report must be made available to a user of a packaging or a representative of the Department upon request
- 19. The test report, at a minimum, must contain the following information: Name and address of test facility; Name and address of applicant (where appropriate); A unique test report identification; Date of the test report; Manufacturer of the packaging; Description of the packaging design type (e.g. dimensions, materials, closures, thickness, etc.), including methods of manufacture (e.g. blow molding) and which may include drawing(s) and/or photograph(s); Maximum capacity; Characteristics of test contents, e.g. viscosity and relative density for liquids and particle size for solids; Test descriptions and results; and Signed with the name and title of signatory.
Editor's Notes
- #8: No instruction is simple.
- #14: Shippers must be careful to insure that the closure instruction for each different packaging and each different manufacturer, is followed. And since there is no template for how to write the closure instruction, this can be an liability heaped onto the shipper.
- #22: No Torque values or detail of when closure is reached.
- #23: Instruction for Closed Head, plug drums. What’s in the box?
- #24: Good step to use an illustration.
- #25: Very vague.
- #26: This is for real!
- #27: Multi-Closure instructions from a single distributor, you have to know the manufacturer to use the correct instruction – GBC.
- #28: Do you know M4453?
- #29: What about M4723?
- #30: Guess who is SDCC? Skolnik!