Aspects of Safety Assessments for Package Designs with Additional Equipment Components

Many paragraphs in TS-R-1 [1] contain the terms “package” or “packaging”. These terms are defined in TS-R-1 paras 230 and 231 and explained in TS-G-1.1 [2] paras 230.1 – 230.6. The importance of a consistent understanding of these definitions has been shown by recent discussions during the assessment of applications for package design approval. There was disagreement, if equipment components attached to the container body during transport, e.g. a transport frame, should be considered part of the package and taken into account in the safety assessment for the package. Discussions were also caused by the way inner design components are treated in the safety assessment of the package. This paper summarises the regulatory requirements to such additional equipment components and presents the way of their inclusion into the package design approval process in Germany.