Recent Issue Summaries
What You've Missed... January / February 2008 Issue
A sampling of what you've missed in the January / February 2008 issue of HAZMAT Packager & Shipper...
As a Subscriber, you would have learned ....
about the importance of avoiding the confusion some experience in trying to understand when materials should be or should not be considered hazardous materials for shipment. A wrong decision here can lead to a finding of non-compliance by DOT inspectors. Learn how materials, though listed by name in the Hazardous Materials Table (49 CFR 172.101), under some circumstances need not be considered as hazardous materials under the DOT rules. Read more. Comments on DOT Letters of Interpretation: Section 173.217
about the many varied subjects the UN Transport of Dangerous Goods Sub-Committee is addressing that will lead to the next changes in the UN Orange Book and the DOT rules. Topics under review include in vitro skin corrosion standards, a re-addressing of consumer commodities and limited quantities, a study on flammable liquids vapor permeability of plastics packaging, portable tanks changes, adoption of new ISO standards for welded cylinders, ultrasonic examination of cylinders in place of hydrostatic testing without a need for competent authority approval, and many others. Read more UN Meetings in Geneva
about the many new changes effective January 1, 2008 in an article designed to allow readers to quickly review this voluminous rulemaking of more than 41 Federal Register pages. Changes to the Division 6.1 and Class 3 and Class 8 definitions are among the many items highlighted. Read more. Docket HM-215I Review
the details about the implementation of new federal security regulations for high-risk chemical facilities. Any facility that possesses one or more chemicals of interest (“COIs”) must submit to the Department of Homeland Security a “Top-Screen” document, by January 22, 2008 or within sixty days of coming into possession of a COI. Don’t let the name fool you: the regulations cover more than typical chemical facilities. Identified high-risk facilities must comply with so-called CFATS, meaning that they must come into compliance with risk-based performance standards. This first step requires any facility that possesses chemicals to determine if it must comply with the CFATS regulations. Read more Security Regulations for Chemical Facilities
about where the DOT Pipeline and Hazardous Materials Safety Administration (PHMSA) is headed. Learn what its new administrator sees as most demanding of his attention and how he plans to approach industry in addressing issues and problems. Glean what are new developments are on the horizon in the enforcement arm of the Administration,. Find out about the timing of new rules relating to the new Globally Harmonized System of Classification and Labeling of Chemicals (GHS). Read about the status of various rulemakings in progress. Read more DOT announcements made at a recent DGAC meeting
that a question regarding the acceptability of using water to conduct vibration tests on IBCs destined to contain liquids, have arisen once again. A recent DOT interpretation letter casts doubt on whether HM-231, expected to resolve this issue, will in fact do so. The final rules in DOT Docket No. HM-231 are expected to be issued momentarily. Read more Vibration Testing of IBCs with Water
about an unusually large number of shipping paper entry changes for shipments by air, particularly with regard to describing the quantity of hazardous materials in the shipment, that were introduced by DOT Docket HM-215I. Read more Docket HM-215I Review
that the UN experts are on the brink of achieving an international harmonization victory with a reduction of identification requirements for limited quantity shipments. It is the author’s opinion that this change is a vast improvement for ID 8000 consumer commodities. The UN proposal for limited quantities provides for no shipping paper for highway and rail and for a special package mark that provides no indication of hazard (like ORM-D’s in the US). The author questions whether these changes are acceptable from both a safety and logistical perspective. Read more UN Is Close to a Decision on Revised Limited Quantities Requirements
about the serious problems that face the DOT specification packaging user if one marks DOT specification packagings for the highest packaging performance level allowed in the regulations for any hazardous material, the so-called “macho” markings. Find out the details about why this could be a serious problem with heavy implications. Learn what DOT is doing in tracking down these users and packaging manufacturers and what is in store for them. Read more Problems with High Level DOT Specification Packaging Markings
about a new requirement traditionally applied to combination packagings to display orientation arrows, which recently has been extended to single packagings fitted with vents and to open cryogenic receptacles. Read more Docket HM-215I Review