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Recent Issue Summaries

What You've Missed... May / June 2007 Issue

A sampling of what you've missed in the May / June 2007 issue of HAZMAT Packager & Shipper...

As a Subscriber, you would have learned ....

that obligations of third party providers like freight forwarders, transportation brokers, etc., as seen by the DOT, may come as a surprise based on a recent DOT letter.  Detailed security plan compliance is called for though they may not physically handle the goods themselves.  Such offerors of a hazardous material are required to develop and to implement plans “addressing personnel [security], unauthorized access, and en route security”.  Moreover, although not specifically mentioned by the DOT, under the rules the plan also must include “an assessment of possible transportation security risks...and appropriate measures to address the assessed risks”, a daunting task for many such third parties. 

    that the many public comments submitted to the draft revised ICAO packing instruction changes may have never been seen or considered by most of the members of the ICAO Dangerous Goods Panel as it moves forward to change its Packing Instructions in significant ways.

    that an ICAO DGP working group continues to re-evaluate the general philosophy relative to the carriage of dangerous goods on cargo-only aircraft   A consensus appears to be emerging.   As an alternative to the current “accessibility” requirement for the loading of cargo aircraft only materials, such materials possibly could be safely loaded and transported in inaccessible cargo compartments meeting “Class C” cargo compartment standards.

    that a limited select group of ICAO Dangerous Goods Panel (DGP) members have been formulating the basis for critical decisions being made about the changes in the new ICAO Packing Instructions.  The Panel’s decision-making documents are being presented without most of the DGP members (government representatives) seeing the great majority of the comments ICAO has received.  In fact, the Panel has only been presented with two from the many comments the public at large has made. 

    that a recent DOT rule change proposal, Docket HM-218E, should be of highest interest to persons using mobile refrigeration systems, and cylinders and their valves.  Of equal interest should be DOT’s latest proposals regarding the determination of  toxic gas mixtures, tube trailers, stowage of Class 2 in reefer units aboard vessels, cylinder manufacturing, and cylinder requalification. 

    that the Occupational Safety and Health Administration (OSHA) on April 13, 2007, published a Notice of Proposed Rulemaking (NPRM) on explosives.  It is of interest to more than just the explosives industry. Consider that OSHA states in the preamble, that it “views its statutory authority to include working conditions during the actual movement of hazardous materials, as well as during the preparation of hazardous materials prior to movement, and the loading, unloading, and temporary storage of hazardous material incidental to movement.”  Readers will want to follow this one closely. 

     that a recent DOT notice of proposed rulemaking, Docket HM-218E, about cylinder valves could significantly affect the use and cost of valves on many cylinders containing ANY hazardous materials. 

    that the recently published final rules in DOT Docket HM-215F may be anything but a user-friendly consolidation of the rules covering international shipments.  This is how DOT describes the Docket.  Readers will be surprised at the introduction of the many new requirements especially for foreign shippers, and for some US carriers also.  International reception could be sizzling and threatening to continued cooperation in having shipments be mutually acceptable between countries.  

    that PHMSA is now working more closely and more actively with the National Transportation Safety Bpard (NTSB) in an effort to arrive at a hazmat transportation system that encompasses all  aspects of loading, storage and unloading under a comprehensive regulatory system.