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A sampling of what you've missed in the May / June 2009 issue of HAZMAT Packager & Shipper...
As a Subscriber, you would have learned ....
about the May 4 to 8, 2009, ICAO Dangerous Goods Panel working group meeting in Auckland, New Zealand that discussed potential changes to the 2011 – 2012 ICAO Technical Instructions. The working group considered approximately 70 different documents. Many of the proposals discussed will require further follow-up in documents to be presented at the October 2009 ICAO Panel Meeting. The Secretariat is preparing a report of the meeting that will be available on the ICAO website when it is completed. ICAO Dangerous Goods Panel Working Group Meeting.
about a new feature of this Journal. Imagine having someone prepare for you a short, right to the point, executive summary for each UN paper submitted. This is what one of the Journal’s newest staff writers is doing for you. No more reading those lengthy UN papers to understand (many times decipher) how you might be affected. Read this article and see once more how the Journal brings you news and information in a form and content that no one else gives you. UN Transport of Dangerous Goods June 2009 Sub-Committee Meeting.
that on May 15, 2009, DHS’s Chemical Security and Compliance Division started the final phase of its implementation of the Chemical Facility Anti-Terrorism Standards (CFATS) by opening the Site Security Plan (SSP) portion of the Chemical Security Assessment Tool (CSAT). The process of submission of the SSP culminates a process started almost three years ago when Congress authorized Homeland Security to identify and regulate security of high-risk chemical facilities to ensure they would be protected against terrorist attack. The author provides valuable information to help understand this new process. DHS Enters the Final Phase of CFATS Implementation.
about DOT’s attitude on several hazmat and packaging issues. PHMSA answers questions on variations in packaging test results between test facilities, on packaging test methods to standardize test criteria, on plastics compatibility testing, on PHMSA’s enforcement plans, on uniformity and consistency in PHMSA’s inspection process, on opportunities for manufacturers to conduct packaging testing at their facilities with PHMSA personnel present, and many other issues. Answers from PHMSA.
about the final rule in Docket HM-218E, Miscellaneous Cargo Tank Motor Vehicle and Cylinder Issues, published by PHMSA in the April 9, 2009, Federal Register. The author reviews the changes and provides much helpful background information associated with them. It includes new tube trailer requirements. DOT Final Rule -- HM-218E: Miscellaneous Cargo Tank Motor Vehicle and Cylinder Issues.
about a surprising interpretation from PHMSA regarding testing of combination packaging and a situation where, although there is no leakage from the inner packaging, DOT considers that in its opinion, the results are that the test was nevertheless a “failure” because of a “potential” for leakage in transportation. Comments on DOT Interpretation letters.
about a May 2009 House of Representatives Subcommittee on Railroads, Pipelines and Hazardous Materials hearing that begins the process of considering amendments to the Hazmat Transportation Act (HMTA). The Subcommittee’s prepared statement describing the purpose of the hearing is telling in that it provides evidence of what Congress has on its mind regarding reauthorization of HMTA. The author makes some very interesting observations about matters that could become new hazmat law. House of Representatives Holds Hearing on HMTA Reauthorization.
About whether a supplier or a downstream distributor, who themselves act as shippers can use the telephone number of the 24 hour emergency response information provided the supplier or distributor has contracted with it. There are weaknesses in the current emergency response telephone number requirements in §172.604 when a third party provider is used. PHMSA attempted to address some of the concerns in an HM-206 rulemaking NPRM issued some time ago. Review this helpful discussion. Comments on DOT Interpretation letters.
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