Recently The Journal of HazMat Transportation posed a number of specific questions to the Pipeline and Hazardous Materials Safety Administration. The Director of PHMSA’s Office of Hazardous Materials International Standards Duane Pfund, and Ryan Posten, Director, PHMSA Office of Hazardous Materials Enforcement both responded to these questions regarding PHMSA’s enforcement and Packaging Evaluation Programs.  The Journal of HazMat Transportation’s questions are prefaced by JHT.

JHT:  One of the innovations that have re-emerged with the OHME program involves the opportunity for manufacturers to conduct packaging testing at their production facilities in the presence of agency enforcement personnel.  While it is understood that PHMSA has observed testing at manufacturer’s facilities in the past, to what extent has this re-initiative been conducted?  What has the agency learned from observing testing in these facilities?  Have there been any surprising results from these observations?

PHMSA Ryan Posten, Director, PHMSA Office of Hazardous Materials Enforcement
PHMSA’s Performance Packaging Validation Testing Program has sampled nearly 400 different non-bulk and IBC designs since 1996.  The U.S. is the only competent authority with a testing program that verifies performance certifications after mass production.  In August 2008, OHME expanded the program to provide the packaging manufacturer with the option to demonstrate performance testing themselves in lieu of independent testing at the U.S. Army - LOGSA, Tobyhanna, PA. 

The primary difference between past demonstration testing at manufacturing plants and our new Alternative Validation Testing (AVT) initiative is that the manufacturer agrees that their test facility will run a full series of HMR certification tests, and PHMSA will consider the results official.  Just as with LOGSA test results, PHMSA may choose to take enforcement action on a case by case basis depending on the number and severity of unit failures.

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