A sampling of what you've missed in the July / August 2006 issue of HAZMAT Packager & Shipper...

As a Subscriber, you would have learned ....

that in Docket HM-220E, DOT adopted UN standards for cylinders and other pressure receptacles. But did you realize that DOT is generally not prepared to “trust” other competent authorities as capable of ensuring that UN receptacles produced within other authorities’ jurisdictions can be accepted in the U.S. as complying with the UN standards to which they are marked and certified. The result is that for all practical purposes any UN pressure receptacle intended for international transport to or from the United States will need approval and marking as required by multiple competent authorities - one being the DOT.

through analysis of DOT’s 2004 annual enforcement report, that one can learn where the training and compliance emphasis needs to be placed so as to reduce the instances of citations a company may receive when encountering inspections by PHMSA. This information should be combined with the related penalty action information about FAA, FMCSA, FRA and USCG enforcement covered in the last issue of HAZMAT Packager & Shipper.

that UN Excepted Quantity Requirements were finally adopted at the UN’s July 2006 TDG meeting. They are to be included in a new Chapter 3.5 of the next edition of the UN Model Regulations (15th edition, post December 2006). The text is available on the UN website. The web address is given in the article.

that an employee closing the discharge valve on a bulk package after unloading in preparation for having a tank picked up by a carrier for return, makes you an “offeror”. This means you must comply with the emergency response information requirements in Subpart G of Part 172 of the HMR, amongst numerous other compliance responsibilities typical of a “shipper”.

important details about the many revisions scheduled for the next UN Orange Book edition (15th). This article describes a large number of changes that were adopted at the last UN TDG Sub-committee meeting held in July 2006 in Geneva Switzerland. Just about all these changes can be expected to be adopted at the December 2006 UN TDG/GHS Committee meeting. You will see them implemented in the near future in the international modal regulations (e.g., the IMDG Code, ADR/RID, ICAO Technical Instructions) and the DOT Hazardous Materials Regulations.

that incoming ocean shipments prepared to meet IMDG requirements and consigned to a facility that stores the material may not be reoffered for further transportation in the United States unless the shipment conforms or is changed to conform to the applicable DOT HMR requirements. The special provisions in 49 CFR allowing import shipments by vessel to be prepared in accordance with the IMDG Code requirements cover the shipments only to the first destination in the United States.

about your responsibilities when bulk packages are picked up by a carrier (motor or rail) for return to the original shipper and the shipping papers are prepared by the carrier or even the original shipper. There can be a misconception that the person presenting the empty bulk package to the carrier for return is not an “offeror” of a hazardous material for purposes of applicability of the HMR. Nothing could be farther from the truth.

that DOT has recently placed 18 sample design type packaging test reports on its website. These samples illustrate report formats for various types of non-bulk packagings (e.g., metal drums, plastic drums/jerricans, fiberboard boxes, etc.) as well as present a sample test report format for the inner receptacles/packagings of composite and combination packagings. Were you aware that DOT has already imposed these comprehensive detail requirements on a significant number of testing companies for them to be considered in compliance with DOT’s packaging recordkeeping requirements?