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Recent Issue Summaries

What You've Missed... September / October 2007 Issue

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

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

    that the author of the limited quantity article in this issue has provided a very helpful and extensive overview of the distinctions between the DOT limited quantity and ORM-D regulations.  This results in a compact and meaningful summary of the advantages and limitations of each of the different marking systems, which includes their application and limitations in international transport by air and water.  Does a Generic LQ Mark for Limited Quantities Offer any Benefit

    that recent Coast Guard correspondence has re-affirmed that technical name markings are not required on portable tanks.  The marking requirements for shipping names on portable tanks have confused a number of people.  The author discusses these marking rules and includes for our readers, a copy of the Coast Guard letter.  Shipping Name Markings on Portable Tanks

    that in a new letter about changes in closure tape as it affects design type, DOT provides a suggested solution that involves annotation of a combination packaging design type testing report.  This is a new option offered by DOT to this dilemma in which box closers often find themselves when using a different tape.  The example involves a different width of tape.  Comments on DOT Letters of Interpretation; Sections 173.22 and 178.2

    about the various attitudes and plans of the Federal Motor Carrier Safety Administration for a national “Safety Summit” on cargo tank roll-overs.  It indicates a lack of interest in moving forward with satellite tracking and traction control systems for commercial motor vehicles.  It presents the administration’s approach to any concerns for the new laws on opening packages and in stopping transport of a hazmat shipment if an inspector deems a shipment poses an imminent hazard.  Questions for the Federal Motor Carrier Safety Administration

    that a critical decision about consumer commodities is now being debated at the UN.  It could have an enormous effect on the transportation of ORM-D materials, a hazmat entity that is currently recognized only in the United States.  The author points out how important it now is for the industry to become involved in participating in the formulation of the new regulations that could result from this activity.  Does a Generic LQ Mark for Limited Quantities Offer any Benefit

    that there may be serious concerns with a proposal by an ICAO “working Group” to change the ICAO Packing Instructions as we know them today.  Readers will want to examine this move carefully which some believe, could lead to more problems than are resolved by the proposal.  The author’s observations help evaluate the situation.  The Latest Round in the Revisions to the ICAO Packing Instructions

    that the text explaining exceptions from incident reporting appearing in the current DOT Guide for Preparing Hazardous Materials Incident Reports are misleading.   In a recent letter, DOT has provided a clear explanation of the intent of the hazardous materials incident reporting exceptions.  DOT plans to clarify the explanation of these exceptions appearing in the incident reporting guide.  Comments on DOT Letters of Interpretation; Section 171.16(d)

    that by studying the DOT penalty reports and understanding the violations brought against companies, such reviews can shed light on what DOT inspectors are focusing.  This examination can help company compliance personnel correct deficiencies in their own operations before they are faced with a DOT inspection.   Training can also be more focused by this awareness.  Summary of DOT’s FY2005 Hazardous Materials Penalty Action Report

    that DOT provided a helpful interpretation on the packaging exceptions for “waste materials” in § 173.12(c) of the Hazardous Materials Regulations (HMR).  These exceptions apply to all wastes, not just to “hazardous wastes” subject to the EPA Hazardous Waste Manifest requirements.  Thus, many companies may re-deploy empty drums in which they have received product, but the author notes especially that the closure instruction rules continue to apply.  Comments on DOT Letters of Interpretation; Sections 173.12(c) and 173.28

    that packages meeting the ORM-D marking requirement and having no other hazmat markings typically are not suitable for international transportation.  However, the DOT regulations do not preclude dual marking.  It is permissible to mark a package with both the international limited quantity marking as well as the ORM-D mark.  Does a Generic LQ Mark for Limited Quantities Offer any Benefit