Recent Issue Summaries
What You've Missed... November / December 2007 Issue | What You've Missed... November / December 2007 Issue |
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A sampling of what you've missed in the November / December 2007 issue of HAZMAT Packager & Shipper... As a Subscriber, you would have learned ....
why the display of the new GHS pictograms could result in the delay or frustration of shipments. Learn how, on non-DOT HMR regulated packages, there could be a serious compliance issue for carriers. Comments on DOT Letters of Interpretation: Sections 172.401 and 172.407 that third parties such as contractors and consultants performing offeror or transportation functions on behalf of another party must independently comply with DOT regulations including registration, training and security plan requirements. Comments on DOT Letters of Interpretation: Sections 107.601, 171.1, and 172.800
that the latest round of IMDG Code amendments are about completed. New requirements for the classification of materials hazardous to the environment are included. Classifying materials for their environmental hazards will make hazardous materials classification considerably more difficult. Learn that DOT intends to implement similar requirements consistent with the IMDG Code effective date. IMO DSC Subcommittee -- Dangerous Goods By Vessel how to find numerous alternatives in the DOT Hazardous Materials Regulations for shipping hazardous materials. Shippers need to familiarize themselves more with the many exceptions from regulation that are provided. The writer believes that many options available for shipment in other than specification packaging are overlooked. Similarly, many reliefs from regulation under special operating circumstances are frequently forgotten. Small Quantity Shipments that the ICAO Panel has adopted revised Packing Instructions for air shipments. They are expected to be approved in Spring 2008 and will become mandatory January 1, 2011. Shippers will need to review the new packing instructions in tedious detail to identify changes. While in many cases packagings currently not authorized for certain dangerous goods will be permitted under the new system, some dangerous goods packaging options will be eliminated or quantities reduced under the new system. Revised ICAO Packing Instructions
about a recent DOT clarification letter that very effectively illustrates the proper use of the DANGEROUS placard and how these placarding requirements and exceptions are to be applied. The author believes that the letter is particularly helpful because the information is presented more clearly than the regulations themselves. Comments on DOT Letters of Interpretation: Section 172.504 how the DOT HMR rules should be used when applying them to stretch- and shrink-wrapping as this technique is applied to the shipment of limited quantities and consumer commodities. Comments on DOT Letters of Interpretation, Sections 171.8 and 173.25 that revised ICAO packing instructions will all have numbers different from those in the current system. Lead time will be necessary to modify computer systems used to generate shipping papers to include the new packing instruction numbers, and to ensure that employees are appropriately trained in the use of the new packing system. Revised ICAO Packing Instructions |
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