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Recent Issue Summaries

What You've Missed... November/December 2011 Issue

A sampling of what you've missed in the November/December 2011 issue of HAZMAT Packager & Shipper...

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

that in Docket 216B, PHMSA proposes to adopt special permit SP 12095 into the regulations.  Translating special permit requirements into regulatory text, however, often discloses “hidden defects” within the special permit itself.  The public must and should review the proposed text in the context of apprising the agency so as to result in more informed decision making.  In this article, the author provides guidance to our readers.  SP 12095 -- From a Car Owner and Tank Car Facility Perspective.

about a recent issue concerning closures that are not used when filling a packaging such as a steel drum.  The filler may have no need to remove a lid incorporating a 2-inch closure and may ask the drum manufacturer to close the open head in accordance with the closure instructions.  Does the filler still have a responsibility for verifying the “untouched” open head lid closure in accordance with the closure instructions?  Or is he only responsible for the 2-inch closure he used?  Our readers filing drums need to acquaint themselves with this issue.  Who Is Responsible for Carrying Out Closure Instructions?

about the increased global scrutiny related to lithium battery regulations.  As the level of scrutiny has grown, the impetus for additional regulation or agency action has increased.  This article provides a brief overview of the findings of the UAE General Civil Aviation Authority Emirates (GCAA) Interim Report on the September 3, 2010, UPS Flight 6 crash.  The authors revisit PHMSA’s proposals under HM-224F and highlight the increased efforts in the U.S. to enforce lithium battery regulations.    Charged Atmosphere: Transportation of Lithium Batteries.

about several issues that have recently come to light concerning compliance with the hazmat training requirements.  They include WHO should certify the training of hazmat employees, HOW does an employer certify compliance, WHAT constitutes maintenance of adequate training records.  The author provides invaluable considerations in addressing these questions.  Hazmat Training Questions.

about the outcome of the twenty-third session of the ICAO Dangerous Goods Panel meeting held from October 11 to 21, 2011.  Significantly, this meeting concluded with the amendments to the ICAO Technical Instructions that will be reflected in the 2013-2014 edition and consequently in the 54th edition of the IATA DGR, effective  January 1, 2013.  This article notes the major final decisions reached.  A Review of the Decisions of the ICAO Dangerous Goods Panel Meeting.

about a new consumer commodity marking problem.  With the changes introduced by HM-215K, the ORM-D marking will be phased out over the next few years.  PHMSA is saying that after December 31, 2013, the words “consumer commodity” may no longer appear on a package in association with ORM-D.  The question is -- What happens after that date to packages so marked, already in shipment or in inventory?  ORM-D Consumer Commodity Marking on Packages after December 31, 2013: What happens to Packages Still in Inventory Bearing That Mark.

about the November 28 to December 7, 2011 UN TDG Sub-Committee meeting in Geneva, Switzerland, to develop the 18th revised edition of the Recommendations on the Transport of Dangerous Goods Model Regulations.  The article identifies and summarizes twenty-six formal proposals in five general topic areas.  A number of informal documents are slated for coverage and several of these topics are noted as well.   A Review of Proposals Submitted to the UN Sub-Committee of Experts on the Transport of Dangerous Goods at the 40th Session.