Recent Issue Summaries
What You've Missed... July / August 2008 Issue
A sampling of what you've missed in the March / April 2008 issue of HAZMAT Packager & Shipper...
As a Subscriber, you would have learned ....
that after many years of discussion about the transport of limited quantities and consumer commodities, the UN Sub-Committee has finally reached agreement. Under the concepts developed, a single, generic marking for all limited quantities was developed under which “consumer commodities” are to be subsumed without any distinction. UN TDG Sub-Committee Considers Amendments to UN Model Regulations
that the definition of “Repaired IBC” in 1.2.1 of the UN Model Regulations was revised to require replacement inner receptacles of composite IBCs to conform to the “original design type from the same manufacturer”. The current text requires only that the replacement inner receptacles conform to the “original manufacturer’s specification”. Decisions of the UN Sub-Committee of Experts on the Transport of Dangerous Goods
that an amendment was adopted by the UN TDG Sub-Committee revising the provisions for the data plates for portable tanks for liquids, solids, and gases, and for MEGCs. Now, only the information required on the data plate is to be listed. New figures illustrating an “example” format in which this information could be displayed are included. Also adopted were special transitional provisions for tanks marked to the current UN requirements. Decisions of the UN Sub-Committee of Experts on the Transport of Dangerous Goods
that after evaluating a product and finding that it meets none of the classification criteria for dangerous goods, there are still serious concerns for safety. It is incumbent on the shipper to properly package the product to ensure it will arrive at its destination intact. An incident, and related German proposals to the UN Subcommittee, bring to light conditions you may not be aware your product could face while enroute to its destination. Unregulated Goods Can Become Dangerous
about what the person responsible for hazmat classification must consider when classifying mixtures of substances according to the new criteria for Environmentally Hazardous Substances (EHS). There are new criteria introduced under Amendment 34-08 of the IMDG Code. The New IMDG Code Criteria for Classifying Environmentally Hazardous Mixtures
about the many variations one needs to be aware of when deciding whether or not a material is a consumer commodity. For example, use of consumer-type packaging (e.g., bearing all required consumer protection warning marks) is not necessary to meet the definition. If a material or a similar material is sold in some form for use in the home, the material may be considered a consumer commodity even if not intended for such use. Read the author’s enlightening comments about when a hazmat can be considered to be a consumer commodity. Limited Quantities and Consumer Commodities
about a definitional issue concerning flexible IBC packaging that does not have top lifting devices attached. This discussion might surprise persons handling this kind of packaging. Such IBCs on pallets might or might not meet the criteria for a UN specification flexible IBC. This article guides one in distinguishing between authorized and unauthorized packaging of this type. Comments on DOT Interpretations
about whether a shipper of hazardous materials should maintain copies of DOT test reports for the performance-oriented packagings the company purchases and fills with its products. Comments on DOT Interpretations
that on July 7, 2008, PHMSA published its latest regulatory notice in an effort to improve the integrity of combination packages used in air transport. The author presents his perspective on the rulemaking and provides insight on why affected businesses shipping by aircraft should be aware of the basis for the rulemaking. It could significantly affect packaging costs. He points out how it is not clear that the anticipated new requirements will have any effect on solving the perceived problem. Perspectives on PHMSA’s Advanced Notice of Proposed Rulemaking on Air Packaging for Liquids