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

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

that DOT holds responsible those companies that contract out the preparation of Hazardous materials for transportation, not only for the specific offeror functions the contracting company performs, but also for the accuracy of the basic underlying information provided to the third party contractor, which then the contractor uses in making the shipments.

using reconditioned, repaired or remanufactured packaging (including IBCs) requires some extra care and awareness on the part of the user (shipper) to assure that the packaging is as reliable and compliant as new packaging.

about the UN Model Regulation amendments being considered for incorporation in what will be the Fifteenth Revised Edition of the UN Recommendations. These are the changes that, if adopted, one would then expect to see implemented in the international modal regulations (e.g., the IMDG Code, ADR/RID, ICAO Technical Instructions) and national regulations on or about January 1, 2009.

why some new drum manufacturers are not happy with the drum reuse situation with respect to compliance with the DOT/UN specification regulations and the original certification that they apply to drums.

about several IBC changes affecting construction and design type testing that are being considered by the UN in the next couple of meetings (July and December 2006).

that IATA is proposing a change to Packing Instruction P650 - applicable to Category B Biological Substances - which would subject persons preparing and offering such materials for transportation to the full hazmat training requirements. If adopted, this could prove problematic for many medial facilities - including doctor’s and dentist’s offices - and for the use of home diagnostic kits.

that France proposes to amend the drop test provisions for all types of packagings by adding a reference requiring the impact surface to conform to the requirements in ISO 2248. France maintains that this would then clearly define the characteristics of the impact surface.

that a concern with cargo securement systems assembled from wood is the lack of consistency. The performance of a wood system relies heavily on the skill level of the installer and the quality and moisture content of the lumber. Strapping systems and manufactured cargo restraint devices can provide the consistency required to responsibly manage the risk associated with load shift of hazardous cargo.

that through analysis of DOT’s 2004 annual enforcement report, one can learn where the training emphasis should be placed to reduce the instances of citations a company may receive when encountering inspections by FAA, FMCSA, FRA and USCG enforcement personnel.

that lumber-based cargo securement systems are required to be heat-treated or fumigated and that the dunnage must show the International Plant Protection Committee (IPPC) mark per the International Standards for Phytosanitary Measures (ISPM-15) requirements. This certification and marking of solid wood packaging material is required on all shipments.

how industrial containers such as steel and plastic drums and IBCs, sent to a scrap yard or other industrial facility with hazardous residue, may expose a company to full Superfund cleanup liability. Under CERCLA (Comprehensive Environmental Response, Compensation, and Liability Act), people who arrange for such disposal may be held liable for clean up of any site where those substances are released and cause environmental contamination.

that a proposal is being presented at the next July 2006 meeting to change the UN Model Regulation (Orange Book) to allow for up to 500 ml or 500 grams of pharmaceutical samples each less than 1 gram or 1 ml in size, to be excepted from the Dangerous Goods regulations provided certain packaging requirements are met.

why used open-head drums create more of a problem for reliable recertification than do closed-head drums.

about DOT’s opinion on how a UN standard packaging (such as a UN 4G fiberboard box packaging) can be reclosed by taping over the old tape with new tape and yet under certain conditions remain within specification.