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Recent Issue Summaries What You've Missed... September / October 2009 Issue
Recent Issue Summaries What You've Missed... September / October 2009 Issue | What You've Missed... September / October 2009 Issue |
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A sampling of what you've missed in the September / October 2009 issue of HAZMAT Packager & Shipper... As a Subscriber, you would have learned .... about a May 2009 meeting between a group of third-party laboratories, government agencies and container manufacturers working together towards standardized and consistent UN packaging test methods. It is clear that there are inconsistencies in test methods between various laboratories. There are also interpretative differences of opinion as they relate to packaging test procedures. Read about what is being discussed.Third-Party Testing Laboratories and Standardizing Packaging Test Methods. that the Transportation Security Administration (TSA) has recently published an interim final rule (IFR) establishing a certified cargo screening program (CCSP). This rule is to ensure that 100% of cargo placed on passenger aircraft in the United States has been screened. A clear understanding of this new rule will enable shippers that transport cargo via passenger aircraft to minimize bottlenecks in their shipment processes. The IFR will be effective on November 16, 2009. Certified Cargo Screening Program -- Interim Final Rule. about an October 10, 2009, hearing by the House Committee on Transportation and Infrastructure, criticizing PHMSA’s management of its hazardous materials transportation safety program. Data presented in the hearing was based on a report by the DOT’s Inspector General and preliminary findings of the Committee staff’s investigation. Both reports were particularly critical of PHMSA’s handling of the Special Permit and Approvals processes. Concerns with Hazardous Material Safety in the US. about when a packaging that formerly contained a flammable gas is considered to be empty. What if a flammable gas is present but it is below the lower explosive limit? If below the lower explosive limit, is a DOT specification package required to be used? The author examines a recent DOT interpretation letter and raises a number of interesting issues about the agency’s reply. Comments on DOT Interpretation Letters. about an action plan that DOT has developed which could mean potentially serious problems arising in PHMSA’s Special Permits and Approvals programs. As a result of a DOT Office of Inspector General (IG) Investigation and a recent critical hearing by the House Transportation and Infrastructure Committee, PHMSA has developed an action plan you will want to see, to address the many issues raised. PHMSA Issues Action Plan on Special Permits Program. about subjects slated for discussion in an upcoming ICAO Dangerous Goods Panel (DGP) meeting to consider amendments to the ICAO Technical Instructions. Its work will determine the content of the 2011 – 2012 edition of the ICAO TIs. Adopted amendments will also be included in the 2011 edition of the IATA Dangerous Goods Regulations and will likely affect air transport requirements in the HMR. A Review of ICAO DGP 22 Issues. about items discussed in the most recent London meeting of the International Maritime Organization (IMO) Subcommittee on Dangerous Goods, Solid Cargoes and Containers (DSC). During its meeting, the DSC made decisions relating to IMDG Code content. These amendments to the IMDG Code will be included in Amendment 35-10 which will take effect on a voluntary basis on January 1, 2011 and become mandatory on January 1, 2012. IMO DSC Subcommittee to Hold its 14th Session. that PHMSA is strongly pushing strict resin specification compliance in plastics packaging manufacture. DOT says that resins used in the manufacture of UN-certified plastics packaging must be absolutely identical with the resin tested in the design specification testing process. In this article, the author explores why this is not practical nor realistic to the degree sought by DOT. The author reports on a recent DOT/Industry meeting indicating that DOT is reluctant to acknowledge the industry viewpoint. Implications of Current PHMSA Position on Manufacture of Plastic Packagings. about the potential for conflicts created between state-implemented environmental regulations and national transportation regulations. A questioner asked DOT whether it is appropriate to treat a State designated hazardous waste as if it were an EPA hazardous waste for purposes of compliance with the HMR even though the substance is not included by name on the EPA hazardous waste list. DOT’s answer may be puzzling to some and you may want to pursue this issue further if you have a hazardous waste designation issue between State and federal rules. Comments on DOT Interpretation Letters. |
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