Tis‘ the season for acknowledging our blessings and expressing thanks to those who have helped us to reach another year. For years, I have brought incidents and ideas to your attention in order for us to further protect our loved ones from careless and unintentional dangerous goods accidents. And therefore, I want to express my thanks to some of the regulatory specialists, professional staff, associations and fellow business persons that have joined with me to highlight and inform the SKOLNIK customers and friends of methods to improve transport safety. To the US DOT, I thank Fritz Wybanga, Bob Richard, Ed Mazzullo, Del Billings, Jim O’Steen, Doug Smith, Kevin Boehne, and my local sounding board, Skipp Skeggs. From the UK, thank you to Martin Castle of PIRA and Peter Mackay of the Hazardous Cargo Bulletin. To Al Roberts, Vaughn Arthur and Michael Morrisette of the Hazardous Materials Advisory Council and Larry Bierlein of the Conference on Safe Transportation of Hazardous Articles. Thank you Chief‘s John Eversole and Gene Ryan of the Chicago Fire Department. From the Reusable Industrial Packaging Association, Paul Rankin provided a great foundation for discussing the effects of regulatory change on industry, and CL Pettit helped to secure the basis for many of the issues in question. And to Richard Rubin, Gerry Kefalinos, Haldis Fearn, Richard Rudy, Barry Wingard, Phil Dworsky, Robert Gurman and my colleagues at Skolnik. This is a broad array of knowledge and talent that have helped to make the SKOLNIK NEWS NETWORK a valuable tool in the hazardous materials community. Happy, Healthy Holidays and Thank You ALL!
Drum It Up! Steel Drum Industry News, Trends, and Issues
Archive for 2000
Of all the items ever published in this Newsletter, I am repeatedly asked about "Are you as good as your Dog?" Indeed my personal favorite, I hope you will find in it, a special message for this Holiday Season. Enjoy it again!! ARE YOU AS GOOD AS YOUR DOG???? (May 1999)
Though not our usual forum for expressing personal views, I lifted this from a recent Ann Landers reader: Enjoy! "If you can start the day without caffeine, If you can get going without pep pills, If you can resist complaining and boring people with your troubles, If you can eat the same food everyday and be grateful for it, If you can understand when your loved ones are too busy to give you any time, If you can overlook it when something goes wrong through no fault of yours and those you love take it out on you, If you can take criticism and blame without resentment, If you can ignore a friends limited education and never correct him, If you can resist treating a rich friend better then a poor friend, If you can face the world without lies and deceit, If you can conquer tension without medical help, If you can relax without liquor, If you can sleep without the aid of drugs, If you can honestly say that deep in your heart you have no prejudice against creed, color, religion or politics, Then my friends, you are almost as good as your dog!"
From a recent inquiry by a customer shipping PIH drums (Poison by Inhalation), we learned that at a DOT audit, the customer was asked to provide technical information regarding the prevention of the plug Back-Off. By definition, Back-Off refers to the potential loosening of a steel plug after the required torque is reached when closing a drum (See Skolnik October 2000 Newsletter). Indeed, CFR 49, 173.227(b)(2)(ii) does state that the screw closures must be "physically held in place by any means capable of preventing back-off or loosening of the closure by impact or vibration during transportation." After contacting various plug manufacturing companies, we were told that plug back-off was taken into consideration during the product testing. Skolnik then received letter from the plug manufacturers confirming their liability. Skolnik does offer copies of these letters to PIH Drum customers that might want to keep this information in file should a compliance question arise.
This is a common question asked by many companies and transporters that possess raw materials often containing quantities of dangerous goods. In some cases these are materials that need to be packaged and shipped as Hazardous Materials, and in other cases, the materials are being incorrectly shipped as a Hazardous Material. In either case, the expense for making this error can be a costly fine levied by the US Department of Transportation or one of its‘ affiliate agencies. During the 6 month period of April to August 2000, fines totaling more then $175,000.00 USD were collected by the DOT from a courier, 2 food flavoring companies, 4 janitorial cleaning compound companies, 3 chemical distributors, a packaging distributor, 5 explosive manufacturers and 5 hospitals. And what they all had in common was that they were not properly schooled in the identification, transport and/or disposal of their hazardous materials. While the DOT does offer a hotline for hazardous material issues, one can contact their raw material suppliers or transport companies to inquire about the proper hazardous materials transport. Also, Virtual Compliance (VCOM) is an internet service that provides hazardous materials compliance information at www.vcompro.com.
- The transportation of hazardous materials exclusively on private property, to which signs, gates and guard stations prevent public access, is not subject to the Hazardous Materials Regulations.
- If a carrier is present during the time of unloading and the motive power is still attached to the transport vehicle when an incident occurs, the carrier is responsible for submitting an incident report per CFR 171.16. If the carrier has dropped the transport vehicle and the motive power is removed from the premises, the carrier obligation is fulfilled and transportation is ended; thus, the hazardous materials incident reporting would not apply.
- Employees subject to hazardous materials training must be tested for general awareness/familiarization, function specific and safety training in accordance with CFR 172.704. In addition, recurrent training must cover these three primary areas of knowledge. Therefore, an employee must successfully pass initial hazardous materials training in addition to recurrent training. Recurrent training cannot be waived.
- If a hazardous material at ambient temperatures meets the definition of a solid under CFR 171.8 when packaged and offered for transportation, it is a solid material. However, if the solid will likely encounter temperatures in transportation that may cause the material to become a liquid per CFR 173.197(e)(5), then the packaging must be capable of containing the hazardous material in the liquid state.
Tightness in an assembly is predicated on the fact that materials have a tendency to return to their original thickness or length when they are compressed or stretched. A screw-head functions as one side of a clamp and a nut as the other side. Application of torque stretches the screw between the head and the threads that compress the clamped components. Having created conflict within the screw, the inherent tendency will be to return to its shorter length. These pressures maximize frictional resistance and create tightness. Loosening tendencies can be attributed to material yielding, expansion and contraction, shock and vibration. While shock absorbers such as gaskets and washers do prevent or reduce loosening, it is imperative that torque tightness be verified whenever storage or transit conditions might result in loosening.