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CERTIFICATION OF PACKAGING FOR DANGEROUS GOODS
INFORMATION SHEET FOR THE APPLICANTS
Issue 5
15 March 2004
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LEGAL BASIS
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STRUCTURE OF THE CERTIFICTION BODY
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PROCESS OF CERTIFICATION OF PACKAGING FOR
DANGEROUS GOODS
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EXTENSION AND RENEWAL OF THE CERTIFICATE
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CERTIFICATION SUPERVISION
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SUSPENDING AND REVOKING OF THE CERTIFICATE
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THE APPLICANT’S RIGHTS
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CERTIFICATION AND OTHER FEES
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THE DUTIES OF CERTIFIED PRODUCT SUPPLIER
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APPENDICES
1.
LEGAL BASIS
Scope and regulations related to the State system of
research and certification process are determined by the Act
of 30.08.2002 on the compliance evaluation system, see
Dziennik Ustaw No. 166/02, 1360 with further amendments.
COBRO (Polish Packaging Research and Development Centre) is
accredited by Polish Centre for Accreditation, as a
packaging and packaging materials certification body
(certificate of accreditation No. AC 016).
Under the authority from the Ministry of Industry, dated
15.02.1989, extended on 24.09.1990 and 16.07.1992, and
decrees: No. 4 of the Minister of Economy, Labour and Social
Policy dated 06.06.2003 and decree No 40 of the Minister of
Economy and Labour dated 24.11.2004, COBRO is authorized to
carry out certification of packaging for dangerous goods,
IBCs and other large containers.
The above certification is based on the following:
ADR (Accord europé en relatif au transport
international des marchandises dangereuses) – European
Agreement concerning the International Carriage of Dangerous
Goods by Road signed in Geneva, Switzerland on 30.09.1957.
The document was ratified by Poland in 1975 (Dz.U. 1975, No.
35, item 189) and implemented by the Polish Ministry of
Transportation and Home Affairs on 02.12.1983, (decree on
conditions and audit of dangerous goods carriage by road).
RID - (Reglement concernant le transport
international ferroviare des marchandises dangereuses) - The
Regulations Concerning the International Carriage of
Dangerous Goods by Rail. These regulations are governed by
Annex I to the Uniform Rules concerning the Contract for
International Carriage of Goods by Rail (CIM), which
constitute the appendix B to the Convention concerning
International Carriage by Rail (COTIF) of 9 May 1980. This
Convention was ratified by Poland by the Act of Parliament
of 18.10.1984 (Dz.U. 1985, No. 34, item 15) and implemented
by a decree of the Ministry of Transportation of 06.10.1987.
IMDG - International Maritime Dangerous Goods Code
were drawn by the International Maritime Organization and
they are in force in all its member states.
IATA-DGR (International Air Transport Organization -
Dangerous Goods Regulations). The regulations apply and are
enforced in all member states of IATA.
The above-mentioned regulations have been drawn by
multinational experts based on specific conditions present
in a given means of transportation and they follow the UN
recommendations on carriage of dangerous goods. The carriage
recommendations were drawn by the Expert Committee and
examined by the Economic and Social Council in the session
of 26.04.1957 (Resolution 645 G XXIII).
Dangerous
goods
are those articles or substances which, due to their
physical or chemical properties, could, during
transportation, storage or reloading, cause death, loss of
health, personal injury, and damage, destruction of goods or
environmental contamination.
The articles and substances that are called
dangerous
goods are divided into hazard classes, which identify
the threats they may cause in transportation.
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Class 1 – Explosive substances and articles,
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Class 2 – Gasses,
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Class 3 – Flammable liquids,
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Class 4.1 – Flammable solids, self-reactive substances and
solid desensitised explosives,
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Class 4.2 – Substances liable to spontaneous combustion,
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Class 4.3 – Substance which emit flammable gases in
contact with water,
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Class 5.1 – Oxidizing substances,
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Class 5.2 – Organic peroxides,
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Class 6.1 – Toxic substances,
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Class 6.2 – Infectious substances,
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Class 7 – Radioactive substances,
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Class 8 – Corrosives substances,
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Class 9 – Miscellaneous dangerous substances and articles.
Dangerous
goods
are grouped according to the degree of hazard posed by the
substances:
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Packing group I – Great Danger
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Packing group II – Medium Danger,
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Packing group III – Minor (Low) Danger,
Packing groups
In all international regulations we can find a detailed,
alphabetical list of dangerous goods permitted in rail or
road transport, and information on their classification and
packing requirements.
Packing groups are indicated on the packaging in the
following context:
X – acceptable for Packing Groups I, II and III substances
Y – acceptable for Packing Groups II and III substances only
Z – acceptable for Packing Group III substances only
Scope of certification audit depends on which packing group
the transport packaging belongs to.
COBRO authority does not extend to the certification of
transport packaging of radioactive substances (Class 7),
which fall under the authority of the President of Panstwowa
Agencja Atomistyki (The National Atomic Energy Agency), or
the certification of Gasses (Class 2), certified by the
Director of the Transportowy Dozór Techniczny (The Transport
Technical Inspection).
Product certification follows aspects:
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Full assessment of the product,
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Assessment of manufacturer’s (supplier) quality control
system,
Once the certificate has been issued: auditing stage with
periodical checks of manufacturer’s quality control system
as well as spot checks of products supplied by the
manufacturer or available on the market,
Alternatively, if a batch of products is certified) the
check will consist of:
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Collection of product samples of a certified product
range,
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Full assessment of the product,
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Making sure that the issued certificates are not misused.
Product certification does not release the manufacturer from
the liability for the product and does not cede any part of
this liability onto COBRO.
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2.
STRUCTURE OF THE CERTIFICATION BODY
Certification of packaging in COBRO is processed by the
Packaging Certification Centre, which is autonomous from the
testing laboratories, and directly responsible to the
Director of COBRO. Packaging
Certification Centre is supervised by the Management Board.
It consists of representatives of departments, offices and
institutions involved in the certification process. The main
task of the Board is to draw and supervise the policy
related to the work of the Packaging Certification Centre.
The Board appointed a Technical Committee on packaging
certification. It examines certification applications and
deals with other matters related to certification. The
Committee includes experts in all fields in which the Centre
issues certificates.
The Technical Committee is divided into sections focused on
individual certification fields.
Both the Management Board and the Technical Committee have
an ad-hoc status based on current projects.
COBRO experts take care of certification spot checks and
audit of relevant documentation enclosed with every
certification request. Based on the above they put forward
the application for certification during the Technical
Committee seatings.
A list of experts has been approved by the Technical
Committee.
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3.
PROCESS OF CERTIFICATION OF PACKAGING FOR DANGEROUS GOODS
To have packaging certified with us, you need to fill in the
certification application form
The application form should be accompanied by:
An unambiguous identification of the product in question
(technical documentation or a standard) with a general
description (you need to supply a brief description of:
packaging material, dimensions, volume/capacity and its
technical specifications),
A completed questionnaire with audit of your company, or a
provisional questionnaire on the assessment of the importer
(click here to download the form),
Report on the research performed in the test laboratory
authorized by the Packaging Certification Centre.
You need to enclose technical specifications previously
agreed-upon with Transportowy Dozór Techniczny
(Transportation Technical Supervision) when you apply for
certification for IBCs and large steel, rigid and plastic
containers.
When you apply for the certification of a batch of products:
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you should attach documents describing the batch
characteristics and its unambiguous identification,
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you don’t need to supply the questionnaire with the audit
of your company or the provisional questionnaire on the
assessment of the importer,
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laboratory report must relate to the samples collected by
an appointed COBRO expert.
Certification samples are collected by the test laboratory,
which carries out the research and, when justifiable, they
can be collected by the applying party. The decision on the
above is taken by the manager of the test laboratory which
carries out the research.
When samples are being collected by the applying party, they
will be collected before the board in a random manner and
delivered to the test lab with an accompanying collection
protocol.
Samples to be inspected during the supervision period may
also be collected by an expert appointed by COBRO.
When a batch of products is being certified, samples of an
unambiguous batch will be collected by an expert appointed
by COBRO.
An initial assessment of the application form and enclosed
documentation will be carried out by the employees of the
Packaging Certification Centre.
When the application and documentation enclosed have been
initially approved, the application will be registered. If
requested, the Packaging Certification Centre can issue a
document to confirm the product has been entered into the
certification process.
Certification process begins with the date the application
has been registered.
If the application and documents have been rejected by the
staff member of the Packaging Certification Centre, he will
inform the applying party about the non-compliance and the
certification process will be suspended. The applying party
will need to decide whether to withdraw the application or
to supply missing documentation.
The applying party will supply the Packaging Certification
Centre with all the required documentation, including the
research report. Subsequently, an audit of organizational
and technical environment necessary for long-term and
quality-conscious manufacturing process will be carried out
(if a product manufacturer applies for the certificate).
Alternatively, an audit of organizational and technical
environment necessary for a long-term and quality-conscious
import will be carried out (if an importer applies for a
certificate).
If a batch of products is to be certified, neither of the
above quality audits is required. However, the audit will
focus on the way a batch of products is identified. This
audit can take place when COBRO experts collect research
samples.
Once the audit of an organizational and technical
environment necessary for long-term and quality-conscious
manufacturing process or import has been carried out, COBRO
will assess the application and the accompanying
documentation.
Documentation analysis as prepared by an appointed COBRO
expert will be reported during the seating of the Technical
Committee, which puts forward a motion to issue or refuse
the certificate and passes on its judgment to the Packaging
Certification Centre.
Based on the opinion of the Technical Committee verifying
that the product being certified has met the pre-defined
criteria, a final decision by the Manager of the Packaging
Certification Centre is made.
Certificates for packaging designed for carriage of
dangerous goods are issued for a period of one year.
Certificates for steel and rigid plastic IBCs and for large
steel and rigid plastic containers for the carriage of
dangerous goods are issued for 36 months.
Certificates for IBCs and large containers for the carriage
of dangerous goods others than the ones mentioned above are
issued for a period of one year.
If a batch of products is being certified, the certificate
is issued indefinitely.
In case the application for certification has been rejected,
the Manager of the Packaging Certification Centre will
inform the applying party in writing, stipulating the
reasons and appeal procedures.
Once the certificate has been issued, the certifier signs a
contract with the applying party. The contract will
stipulate the rights and obligations of both parties, and in
particular the following issues:
Supervision of the certification body to guarantee the
certified party fulfils its obligations,
Frequency of supervision checks,
Frequency of laboratory tests,
Rules governing testing of the correct application of the
certificate,
Rules of exchanging information on implemented changes which
would affect both parties,
The duties of the certified party to inform the certifier on
any changes affecting the product, product manufacturing or
organization of quality control system,
Responsibility of the certifier for the confidentiality of
the information received by the employees in the process of
certification (confidentiality clause).
Certification fees and control rules,
Rules governing the revocation and cancellation of the
certificates.
When the contract has been signed and appropriate
certification fee paid, the certificate is handed to the
applying party or, on request, posted.
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4.
EXTENSION AND RENEWAL OF THE CERTIFICATE
The owner of a certificate for packaging of dangerous goods
can apply to have the certificate extended to the varieties
or versions of certified packaging if they do not
significantly differ from the original certified product and
if they fulfil all requirements expected from the original
certified product.
The applying party should submit an application form and the
technical specifications, pointing out the differences
between the product submitted for certification and
certified one.
The extension of the certificate will be granted once the
Packaging Certification Centre has completed the simplified
certification procedure. Its scope as well as details of
accompanying documentation is specified by the Packaging
Certification Centre based on the opinion of the Section
for certification of packaging for dangerous goods of the
Technical Committee.
Application for the renewal of the certificate must be
accompanied by the following documentation:
Application form,
Successful results of laboratory testing,
Successful result of audits carried out by the Packaging
Certification Centre during the supervision period,
Confirmation that full certification process has been
completed.
The deadline for submitting application to have the
certificate extended is two months before the original
certificate expiry date.
In case of positive results of control of certificate usage.
i.e.:
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all elements of the quality system work without
reservation,
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regular quality control sessions are carried and
documented out by the manufacturer or the importer and
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the
register of complaints and faults is maintained.
the expert can put forward a motion to have the certificate
extended without a need to carry out laboratory testing. The
final decision is made by the Manager of the Packaging
Certification Centre.
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5.
CERTIFICATE SUPERVISION
The Packaging Certification Centre supervises correct
application of the issued certificate for the packaging of
dangerous goods throughout the whole period of certificate
validity. There are the following procedures to guarantee
the compliance:
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Spot checks of organizational and technical conditions
necessary for the stable manufacturing process or
quality-conscious import,
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Regular certificate compliance checks,
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Testing of samples collected from the manufacturer or
importer and / or from the end user. The testing is done
at the authorized test laboratories,
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Supervision over the way certificates are used by the
manufacturers or importers.
The company holding a certificate for a given product has to
inform the certification body about any changes in the
product, manufacturing process or organization of quality
control system. The certified company should also maintain
records of all testing carried out in connection with the
certified products, as well as records of claims concerning
the certified product.
An audit is carried out every 12 months; however, they can
be more frequent if there is a need of a corrective action
or if the Packaging Certification Centre has received a
complaint about the quality of the certified products.
The audits verify that:
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The certificate is used in accordance with its purpose and
contract,
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Recommendations given by the experts during the previous
controls were met,
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The structure, components or packaging manufacturing
technology have been maintained since the testing for the
certification process was done,
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The applied control system guarantees production
stability,
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The claims are registered.
Laboratory samples are collected in the auditing process.
Laboratory testing stage can be waived if the audit has
verified, that all system elements work flawlessly, regular
quality control checks are carried out and well-documented
by either the manufacturer or the importer, and a register
of complaints and faults is maintained.
A proposal put forward by an expert can lead to the renewal
of the certificate for another 12 months. The regular
procedure of the UN certificate renewal involves laboratory
testing and a simplified certification process.
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6.
SUSPENDING AND REVOKING OF THE CERTIFICATE
A certificate for a specific product can be suspended for a
period of maximum 6 months in the following situations:
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The certified product does not comply with safety
regulations,
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Failed results of the product testing or failed results of
an audit during the supervision period,
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The certification unit is not allowed to carry out testing
or audit session,
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The party, which has received a certificate for a product
does not adhere to the contract signed.
In the first instance of the above the decision to suspend
the certificate is taken with immediate effect.
The certificate can also be suspended following an agreement
between the Certification Body and the Certificate Owner for
the period of time when the product is not in production or
is not imported, or for any other previously agreed reasons.
The fact a certificate has been suspended will be confirmed
by the Certification Body, and the requirements to have it
renewed will be specified by the Technical Committee. When
the period of suspension is nearly over, the Certification
Body will check if the requirements essential to have the
certificate renewed have been met, which results in the
renewal of the certificate. In adverse situation - the
Certification Body will revoke the certificate.
The Certification Body holds the right to revoke the
certificate if:
The Certificate Owner has abused the certificate licence
terms,
The Certificate Owner has failed to comply within a specific
time span with the conditions set out to renew the
certificate,
The Packaging Certification Centre has received a
certification resignation request issued by the Certificate
Owner.
The decision to revoke the certificate, based on the opinion
of a given section of the Technical Committee, is made by
the Manger of the Packaging Certification Centre. If the
involved party decides to re-apply for the certificate when
it was revoked, a full certification process is carried out.
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7.
THE RIGHTS OF THE APPLICANT
The applicant can receive full information on the subject of
certification (procedures, requirements, costs).
The applicant can resign from applying for the certificate
at every stage of the certification process; however, he
will pay for the costs incurred by the Packaging
Certification Centre up to the moment when the application
is withdrawn.
The applicant can complain against the actions undertaken by
the Packaging Certification Centre in respect of the
certification process. At any stage of certification
process, any complaints are to be addressed to the Manger of
the above-mentioned Centre.
The applicant can appeal against decisions taken during the
process of certification as well as any decisions in the
supervision period, which concern: refusal, suspension or
revocation of the certificate. All complaints can be
directed to the Manager of COBRO within 14 days from the
receipt of the decision from the above-mentioned Centre.
8.
CERTIFICATION AND OTHER FEES
Certification fees can be found in the price list published
by the Packaging Certification Centre enclosed hereby. The
funds due are collected when the certification process has
been completed but before the certificate (document) has
been issued.
The above-mentioned fees do not include laboratory testing
fees which, alongside with supervision fees, are due to the
appointed test laboratory.
Business travel expenses related to the certification
process are charged as per usual.
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9.
DUTIES OF THE CERTIFIED PRODUCT SUPPLIER
The Owner of the Certificate will guarantee the certified
packaging to be identical with those tested in the
certification process.
The Owner of the Certificate will inform the Certification
Body about any changes implemented in the manufacturing
packaging such as, but not limited to: quality control,
construction and technologies used in the manufacturing
process.
The Owner of the Certificate will maintain records of:
all complaints regarding the certified packaging,
all faults discovered in the product and
actions undertaken to remedy the situation.
The Owner of the Certificate will make those records
available at a request of the Certification Body.
The Owner of the Certificate will grant the Certification
Body access to all elements of the quality control system
regarding the certified packaging.
The Owner of the Certificate will pay to the Certification
Body all due fees related to the certification and
supervision of the product, in accordance with the price
list applicable during the process of certification falling
under the scope of this agreement.
10.
APPENDICES:
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A list of test laboratories
authorized to carry out testing of packaging for dangerous
goods within the competence of COBRO, Warsaw.
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Packaging Certification Centre
Price
List
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Certification application form
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Initial assessment form of the manufacturer
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Initial assessment form of the importer
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