In February 2010, the U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA) published HM-231 which detailed the requirements for closure instructions as well as identifying a retention period for closure instructions. Several members of the Council on Safe Transport of Hazardous Articles, COSTHA, noted concerns over the adopted language and requested an interpretation from PHMSA to clarify the requirement to retain closure instructions. It was COSTHA’s contention that closure instructions were required to be retained by each shipper who performs a closure activity, but that shippers who were only forwarding packaging which had not been opened and therefore were not required to be re-closed were not required to maintain closure instructions. This interpretation was validated in an April 11th, 2011 letter issued to COSTHA from PHMSA in which they stated that as specified in 178.2(c)(i)(A), closure instruction notification is required to inform the user of a hazmat packaging of all the requirements the packaging does not meet at the time of transfer. A completed package that is properly closed meets all the requirements contained in its closure instruction at the time it is offered for transportation. If reused, 173.28(a) requires that all packagings used more than once be in such condition, including closures, that they conform to the CFR. Therefore, if the package is not opened and continues to meet its performance standard, the person who received the package and is re-offering it for transportation does not need to retain its closure instructions per 173.22(a)(4). A copy of the PHMSA letter can be found on their web site or here.
STEEL DRUM INDUSTRY NEWS, TRENDS AND ISSUES
Archive for May, 2011
The U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA) has released online its report ranking both the top hazardous materials and transportation processes that were related to serious incidents and fatalities from 2005 to 2009. The Top Consequence Hazardous Materials Commodities Report is part of a series of steps that will allow PHMSA to identify areas of concern, target risks for particular types of hazmat, and plan for future incidents. The report’s data also will help educate enforcement authorities, inspectors and first responders on trends in the transport of hazmat, which will help them set priorities to better deal with the materials and modes of transportation that could have the most damaging effects. The report yielded findings which included: that some hazardous materials have high consequences due to the large number of transports while others are just volatile; that most deaths and injuries can be linked to a small sub-section of hazardous materials; that nearly all hazmat fatalities between 2005 – 2009 occurred during either rail or highway transport; and that rollover and derailment in transit are the principal causes followed by human error. The full report can be found on the PHMSA web site or here.
Having just returned from an extensive trip visiting several of our customer in the beautiful California wine country, we return to Chicago amazed at the abundance and variety of uses of our stainless steel wine barrels. We were pleased to see our 5 gallon stainless steel wine barrel in use in academic and laboratory settings for experimental wine batches and yeast experimentation. The unique size of the 5 gallon barrel and the stainless steel construction make for a perfect small “blank slate” vessel. We were also lucky enough to sample award winning un-oaked Chardonnay, delicate Pinot Noir and citrusy Sauvignon Blanc all crafted with the use of our stainless steel wine barrels. Having once fallen out of favor with American consumers, the Sauvignon Blanc varietal (sometimes labeled as Fumé Blanc) is making a huge comeback in the United States, along with the use of stainless steel fermentation and aging of this versatile wine. While oak-barrel fermentation is often used for Chardonnay, most Sauvignon Blanc is made using stainless steel barrels and tanks. In the Loire Valley of France, wines made from Sauvignon Blanc, such as Pouilly Fumé and Sancerre, are most often 100% Sauvignon Blanc, unblended and usually made without the use of oak. Besides France and California, Sauvignon Blanc also is produced successfully by New Zealand and South Africa, Chile, Argentina, and, to lesser degrees of production, Washington State, Australia, and Italy, where it is expanding. We are happy to note that our stainless steel wine barrels are in use in each of these countries and states!