A sampling of what you've missed in the November/December 2005 issue of HAZMAT Packager & Shipper...

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

that the carrier, not the consignee, is responsible for filing an incident report if a reportable incident occurs while consignee personnel are performing the carrier function of unloading a motor vehicle before the “carrier’s departure” from the premises. A recent interpretation letter appears to remove all ambiguity in relation to this matter by stating unequivocally that it is the carrier’s responsibility to file the incident report in such cases. Comments on DOT Interpretation Letters

that the School of Packaging, Michigan State University conducted side-by-side comparisons between the HMR requirements and tests that simulated actual conditions of air transportation. Many packages did not survive the combined low pressure and random vibration test without leakage including a number while in the HMR-required orientation. The study concluded that problems exist with the performance of Hazmat packaging as being offered for air transportation. Package Testing on Liquid-containing Hazmat Packages

about the Security Sensitive Information (SSI) requirements and whether they apply to Hazmat Security Plans and how and if they should? Requirements for Security Sensitive Information

about many of the specific details of FAA’s new training requirements covering (1) employees that must receive training, (2) what training must be provided, (3) the timing of initial and recurrent training, (4) manual contents, and (5) recordkeeping. The authors describe in very helpful detail how an air carrier must address his obligations to be assured that he is correctly complying with the FAA’s new training requirements. New FAA Hazmat Training Requirements

why the authors think that FAA’s new hazmat training requirements, although an improvement, remain inadequate to secure hazmat safety in air transportation unless the focus is changed. Emphasis by FAA on the enforcement of these requirements before a hazmat incident occurs best ensures the identification and safe transport of hazardous materials in aviation. Focusing on the content of the FAA’s hazmat training regulations should not be the most pressing concern for the FAA’s policy-makers. Will the New FAA Hazmat Training Rule Increase Aviation Safety?

that DOT recently issued an interpretation that unloading of a vehicle is not considered “unloading incidental to movement” even when the driver remains at the facility where the unloading operations are performed. This relates to the driver not being at the actual unloading site where he can “observe” the unloading process., Some might find it judicious to seek further clarification about this matter as it becomes more publicly known, before putting DOT’s letter in practice. Comments on DOT Interpretation Letters

that the next amendment of the IMDG Code will contain a number of UN 14th edition Model Regulation changes including shipping documentation changes to require the UN number-first sequence. Some IMDG changes to certain limited quantity provisions are noted as are certain corrosive materials segregation changes which must be covered by the shipping documentation annotations. The author reports on the fact that compliance with Amendment 33-06 will become mandatory under the Chapter VII of the SOLAS Convention on January 1, 2008. IMDG Code Changes

that the UN Globally Harmonized System of Classification and Labeling of Chemicals system (GHS) will be upon us shortly (January 2007). From impact and compliance perspectives the author advises shippers to consider solids classification now. Solids with toxicities in the 200 to 300 mg/kg range should be identified and preparation should be made to transport them as regulated materials. Toxic materials that will change packing groups due to other changes described should be identified now by shippers. Globally Harmonized System of Classification and Labeling

that while the DOT has issued an exemption authorizing a substitute corrosive materials classification test for evaluating skin necrosis, the costs to a company could be very sizeable if use of this alternative in vitro test causes a major product to be classified as hazardous, when the product may not be required to be so classified according the test criteria prescribed in the regulations. Comments on DOT Interpretation Letters

that DOT has recently issued a Competent Authority Approval to the Members of the Chemical Packaging Committee (CPC). The approval authorizes use of UN4G combination packagings with outer fibreboard that has basis weights that vary by plus or minus 5% from the measured basis weight recorded in the initial design qualification test report for the packaging design type. While DOT appears to be on the road to making fiberboard design type requirements more realistic, it is clear that a number of issues remain to be resolved before this DOT authorization achieves the objectives sought and becomes practical for use. DOT Issues Competent Authority Approval for Fiberboard Boxes