Recent Issue Summaries
What You've Missed... March / April 2005 issue | What You've Missed... March / April 2005 issue |
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A sampling of what you've missed in the March/April 2005 issue of HAZMAT Packager & Shipper... As a Subscriber, you would have learned .... that some European competent authorities argue that consumer commodities defy clear definition, rendering some requirements unenforceable and that the hazards of consumer commodities can be the same as those of other limited quantity materials. Removing provisions for consumer commodities from the UN Model Regulations could have a significant impact. Limited Quantities and Consumer Commodities that in the UN Model Regulations there are many examples of inconsistencies of language, lack of adequate definitions and failure to determine clearly the responsibilities of those involved in the transport chain, e.g., consignors, carriers, consignees. These inconsistencies and vague definitions prevent regulators from simply making the UN Model Regulations mandatory as an existing document. World Convention For Harmonization On and after September 15, 2005, wood packaging materials (e.g. pallets, crates, boxes, and dunnage) imported into the U.S. must be heat treated or fumigated with methyl bromide and marked with the International Plant Protection Convention (IPPC) logo and appropriate country code designating the location of treatment. Wood Packaging Materials that DOT did not support the introduction of a random-only vibration test and will continue to support the position that repetitive shock testing is appropriate as well, both from a results standpoint and the economic standpoint. Measurements taken on the forces that packages in European road transport experience were compared to the forces that a package would experience when tested using the DOT repetitive shock test. It was concluded that the DOT test simulates the forces experienced in European road transport very comparatively. Vibration Testing that in NPRM HM-220E requirements are proposed that would result in manufacturers and users of cylinders and other pressure receptacles to have the option to employ either the UN-based standards, or to continue to apply the existing DOT specifications and associated requirements. Certain advantages would clearly be afforded in electing the UN standard option for international shipments. Cylinder Proposed Rulemaking that FMCSA is focusing on implementing their new hazardous materials permit program to ensure that carriers of extremely hazardous materials have the basic safety and security measures in place to operate. The agency still has a lot of work to do in order to complete compliance reviews and assess safety ratings to carriers applying for a permit that do not have an existing safety rating. HazMat Permit Program that FMCSA is considering a rulemaking to make some technical adjustments to their permitting regulations. The scope of the rulemaking would be to clarify the regulations and adjust the process to make it less administratively burdensome. HazMat Permit Program that the recently completed operational field test commissioned by FMCSA favors implementation of some or all of the tested technologies, particularly Wireless Communications with GPS positioning, for the hazmat trucking industry. The report stresses that a technology must be "fully deployed" for the benefit of these technologies to be realized. Government mandates may be necessary for the hazmat trucking industry to move towards full deployment of these technologies, as the cost will range from $800 to $3,500 per vehicle. Security Technology Testing that in a March 14 decision, the Surface Transportation Board determined that Washington, D.C.'s "Terrorism Prevention in Hazardous Materials Transportation Emergency Act of 2005" is preempted by Federal law (49 U.S.C. 10501(b)). The act would ban transportation of certain classes of hazardous commodities from travel within a 2.2-mile radius of the U.S. Capitol building, unless the D.C. Department of Transportation issues a permit to allow such transportation. Federal Preemption of D.C. HazMat Ban that TSA has published an interim final rule with mandatory security threat assessments of applicants for hazardous materials endorsements. A fee for this assessment has been instituted to cover the costs of the collection and transmission of fingerprints and other necessary information. It is up to the drivers and their employers to determine which of them will pay the fees, totaling about $94. TSA expects that as a result of these fees, certain holders of hazardous materials endorsements will choose not to renew them, resulting in some decrease in the population of HME drivers. Security Threat Assessment Fees |
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