Recent Issue Summaries
What You've Missed... January / February 2008 Issue | What You've Missed... January / February 2008 Issue |
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A sampling of what you've missed in the January / February 2008 issue of HAZMAT Packager & Shipper... As a Subscriber, you would have learned ....
about the importance of avoiding the confusion some experience in trying to understand when materials should be or should not be considered hazardous materials for shipment. A wrong decision here can lead to a finding of non-compliance by DOT inspectors. Learn how materials, though listed by name in the Hazardous Materials Table (49 CFR 172.101), under some circumstances need not be considered as hazardous materials under the DOT rules. Read more. Comments on DOT Letters of Interpretation: Section 173.217 about the many new changes effective January 1, 2008 in an article designed to allow readers to quickly review this voluminous rulemaking of more than 41 Federal Register pages. Changes to the Division 6.1 and Class 3 and Class 8 definitions are among the many items highlighted. Read more. Docket HM-215I Review the details about the implementation of new federal security regulations for high-risk chemical facilities. Any facility that possesses one or more chemicals of interest (“COIs”) must submit to the Department of Homeland Security a “Top-Screen” document, by January 22, 2008 or within sixty days of coming into possession of a COI. Don’t let the name fool you: the regulations cover more than typical chemical facilities. Identified high-risk facilities must comply with so-called CFATS, meaning that they must come into compliance with risk-based performance standards. This first step requires any facility that possesses chemicals to determine if it must comply with the CFATS regulations. Read more Security Regulations for Chemical Facilities about where the DOT Pipeline and Hazardous Materials Safety Administration (PHMSA) is headed. Learn what its new administrator sees as most demanding of his attention and how he plans to approach industry in addressing issues and problems. Glean what are new developments are on the horizon in the enforcement arm of the Administration,. Find out about the timing of new rules relating to the new Globally Harmonized System of Classification and Labeling of Chemicals (GHS). Read about the status of various rulemakings in progress. Read more DOT announcements made at a recent DGAC meeting that a question regarding the acceptability of using water to conduct vibration tests on IBCs destined to contain liquids, have arisen once again. A recent DOT interpretation letter casts doubt on whether HM-231, expected to resolve this issue, will in fact do so. The final rules in DOT Docket No. HM-231 are expected to be issued momentarily. Read more Vibration Testing of IBCs with Water
about an unusually large number of shipping paper entry changes for shipments by air, particularly with regard to describing the quantity of hazardous materials in the shipment, that were introduced by DOT Docket HM-215I. Read more Docket HM-215I Review about the serious problems that face the DOT specification packaging user if one marks DOT specification packagings for the highest packaging performance level allowed in the regulations for any hazardous material, the so-called “macho” markings. Find out the details about why this could be a serious problem with heavy implications. Learn what DOT is doing in tracking down these users and packaging manufacturers and what is in store for them. Read more Problems with High Level DOT Specification Packaging Markings about a new requirement traditionally applied to combination packagings to display orientation arrows, which recently has been extended to single packagings fitted with vents and to open cryogenic receptacles. Read more Docket HM-215I Review |
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