Recent Issue Summaries
What You've Missed... November / December 2008 Issue
A sampling of what you've missed in the November / December 2008 issue of HAZMAT Packager & Shipper...
As a Subscriber, you would have learned ....
about the latest developments regarding final changes being considered at the December UN TDG Sub-Committee and Committee Geneva meetings. These changes are to be adopted in the next edition of the UN Recommendations to be published in 2009. Almost all can be expected to be implemented on or about January 1, 2011. Finalizing Amendments to the UN Model Regulations
about the responsibilities of the various parties involved, where a third-party provider is used to prepare, or assist in preparing, another company’s hazardous materials for transportation. The author describes a DOT letter that is valuable in clarifying the responsibilities of each party engaged in such an arrangement from the aspect of hazardous materials transportation training for employees. You may be surprised at who can be considered a hazmat employee and hazmat employer under these circumstances. Comments on DOT Interpretations
that the conditions and limitations governing authorized inner packaging substitutions under Variation 1 (49 CFR § 178.601(g)(1)) are, actually, quite limiting and rather restrictive and, the author explains, must be interpreted quite literally. He points out why one must not jump to the conclusion that certain substituted inner packagings are inherently “safer” and, therefore, may be substituted for the tested inner packaging. Comments on DOT Interpretations
about DOT’s hazardous materials on-site inspection program. Learn how companies to be inspected are selected and what inspectors are seeking. The author covers the scope of the inspections and what you can expect from any violations discovered. Learn about possible corrective actions by an inspected company and how to be prepared. DOT Inspections: Know What They Are
that as part of the 2005 amendments to hazmat law, the DOT was given a new authority to open packages during transportation. PHMSA issued an NPRM on October 2, 2008, in Docket No. PHMSA–2005–22356 (FR 10/2/2008, page 57281). Several unanswered issues about the opening of packages by DOT inspectors are discussed. The author explains why these need to be addressed by DOT before this rulemaking is completed. This article contains many ideas that may be very helpful in commenting to DOT. HAZMAT Enforcement
about recent deliberations of a UN Transport of Dangerous Goods Sub-Committee working group considering several issues relating to UN standards that govern the transport of lithium batteries. The first meeting of this group was held in Washington, DC on November 11 to 13. The group focused on review of the testing requirements for lithium batteries and assessing differences between small and large batteries and applicable testing requirements. Some of the decisions agreed upon could appear in the next revision of the UN Orange Book. UN Working Group on Lithium Batteries Meeting
that a working group meeting of the ICAO Dangerous Goods Panel (DGP) was held in The Netherlands in early November. The Working Group considered recent work by the UN Sub-Committee of Experts on the Transport of Dangerous Goods covering limited quantities and its implications of this work on the ICAO Technical Instructions regarding air mode “limited quantities”. Readers will want to read the very interesting conclusions on how to distinguish limited quantities in air apart from when shipping these items by other modes of transport. Major marking changes on LQ packages could be coming. ICAO Working Group Considers Revised UN Limited Quantities Provisions
The last issue of Hazmat Packager and Shipper discussed battery issues stemming from the HM-215J/HM-224D NPRM Docket PHMSA issued on July 31, 2008. The battery proposals are part of a much bigger rulemaking so they are easy to overlook. This article discusses many issues about the shipment of batteries as DOT would envision them under new rules. The author provides insightful observations that should be addressed by DOT before it completes this rulemaking. The article contains many ideas that could be helpful in making comments to DOT. Another Look at Battery Issues