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Archive for February, 2018

NEW and Greatly Improved DOT Web Site

February 27th, 2018 by Howard Skolnik

Filed under: DOT/UN, HazMat, Industry News, Skolnik Newsletter

The US Department of Transportation (US DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) recently launched their updated website, www.phmsa.dot.gov. And more recently, under the Regulations and Compliance section of the website, PHMSA added a search feature to the Interpretations page, allowing users to filter Hazmat vs. Pipeline Interpretations and sort by key word, topic, or date range. This search feature is located on the left-hand side of the webpage (see image below). Site visitors can now monitor the Hazmat interpretations, and use the new PHMSA Interpretation search for archived letters.

The site offers navigation tabs organized by About PHMSA, Safety, Regulations and Compliance, and Resources. Recourse highlights include Data and Statistics, including HazMat Incident Statistics. Also highlighted are a number of videos emphasizing current HazMat safety Issues.

2018 New Hazmat Rules At-A-Glance

February 22nd, 2018 by Natalie Mueller

Filed under: DOT/UN, HazMat, Industry News

They say the only thing constant is change and that couldn’t ring more true for those of us in the dangerous goods business. As the transportation, manufacturing, chemical and hazmat industries all keep evolving, so too do the regulations that govern them. At Skolnik, we do our due diligence to ensure all of our products meet, if not exceed, the hefty regulatory standards they face. Part of that due diligence is staying on top of changes to the rules and regulations.

In 2018, a few new rules regarding hazmat containers and shipment will hit the books — here’s a quick look at what those regulations, some of which have already taken effect.

Already in effect:

International Air Transport Associations Dangerous Goods Regulations (IATA DGR), 59th Edition – In effect as of 01/01/2018

Changes include:

  • Stricter requirements regarding air-shipment of lithium batteries

  • A re-organized list of Class 9 materials (see Subsection 3.9.1)

  • A new list forecasting changes for air shippers in 2019 (Appenix I).

Furthermore, IATA has already published an addendum to this year’s DGR that impacts air shippers and airline passengers alike, so look for that as well.

2016 International Maritime Dangerous Goods Code (IMDG Code) — Updates in effect as of 01/01/2018

Reinforces updates that were made in the 2016 edition. Compliance to these updates was voluntary last year, as of this year they are officially mandatory.

Rules include:

  • New dangerous goods marking and labeling criteria

  • New packing instructions for certain shipments of engines, lithium batteries and aerosols

  • Adjustments to the IMDG Code Dangerous Goods list

Coming soon:

Enhanced Safety Provisions for Lithium Batteries by Air (RIN 2137-AF20)  — Expected 02/2018

This Interim Final Rule will harmonize the 49 CFR hazmat regulations with evolving international standards for the air shipment of lithium batteries. International requirements already in effect under the latest IATA DGR will be adopted into 49 CFR.

Rules include:

  • Prohibiting lithium-ion cells and batteries as cargo on passenger aircraft

  • Limiting state-of-charge to 30%

  • Limiting the use of alternate provisions for small cells or batteries by air

Response to Industry Petitions (RIN 2137-AF09) — Expected 02/2018

Currently, parties must petition US DOT to amend, remove or add hazmat regulations to enhance safety/efficiency for shippers and carriers. In 2018, the Pipeline and Hazardous Materials Safety Administration (PHMSA) plans to address 19 of these petitions. This response will likely include new amendments and rules.

 

Miscellaneous Amendments Pertaining to DOT Specification Cylinders (RIN 2137-AE80) — Expected 04/2018

Likewise, DOT will address various petitions from industry stakeholders. These petitions pertain to the manufacture, maintenance and use of DOT specification cylinders. This ruling will incorporate two existing hazmat special permits into the 49 CFR Hazardous Materials Regulations (HMR)

 

EPA’s Electronic Hazardous Waste Manifest System — Roll-out to begin 06/2018

The Hazardous Waste Manifest is a shipping paper required for the transport of hazardous waste, and hazardous waste is regulated in transport by US DOT. While this rulemaking has implications across various industries, here are the consequences specific to hazmat shippers:

The new e-Manifest system will be rolled out on/by June 30th. The EPA plans to utilize the e-Manifest to collect domestic hazardous waste manifests and domestic shipments of State-only regulated hazardous wastes. The e-Manifest system will be funded via user fees for the treatment, storage, and disposal facilities and State-only waste receiving facilities.

Oil Spill Response Plans for High-Hazard Flammable Trains (RIN 2137-AF08) — Expected 07/2018

A Final Rule from DOT to expand the applicability of oil spill response plans for trains transporting Class 3 flammable liquids in specific volumes and orientations across the train. This requirement will apply to High-Hazard Flammable Trains (HHFTs).

These are just the new hazmat rules that are already on the horizon. As always, Skolnik will continue to monitor future regulations or updates that may impact operations, shippers, brokers and carriers, and we encourage all other dangerous goods professionals to do the same.

Doing your due diligence now can prevent a disaster (or hefty fine) later.

What’s News in HazMat Regs?

February 20th, 2018 by Howard Skolnik

Filed under: DOT/UN, HazMat, Industry News, Skolnik Newsletter

It is said that the only thing constant is change, and that couldn’t ring more true for those of us in the dangerous goods business. As the transportation, manufacturing, chemical and hazmat industries all keep evolving, so too do the regulations that govern them. At Skolnik, we do our due diligence to ensure all of our products meet, if not exceed, the hefty regulatory standards they face. Part of that due diligence is staying on top of changes to the rules and regulations.

In 2018, a few new rules regarding hazmat containers and shipment will hit the books — here’s a quick look at what those regulations, some of which have already taken effect.

Already in effect:

International Air Transport Associations Dangerous Goods Regulations (IATA DGR), 59th Edition — In effect as of 01/01/2018. Changes include:

  • Stricter requirements regarding air-shipment of lithium batteries
  • A re-organized list of Class 9 materials (see Subsection 3.9.1)
  • A new list forecasting changes for air shippers in 2019 (Appenix I).

Furthermore, IATA has already published an addendum to this year’s DGR that impacts air shippers and airline passengers alike, so look for that as well.

2016 International Maritime Dangerous Goods Code (IMDG Code) — Updates in effect as of 01/01/2018. Reinforces updates that were made in the 2016 edition. Compliance to these updates was voluntary last year, as of this year they are officially mandatory. Rules include:

  • New dangerous goods marking and labeling criteria
  • New packing instructions for certain shipments of engines, lithium batteries and aerosols
  • Adjustments to the IMDG Code Dangerous Goods list

Coming soon:

Enhanced Safety Provisions for Lithium Batteries by Air (RIN 2137-AF20) — Expected 02/2018.
This Interim Final Rule will harmonize the 49 CFR hazmat regulations with evolving international standards for the air shipment of lithium batteries. International requirements already in effect under the latest IATA DGR will be adopted into 49 CFR. Rules include:

  • Prohibiting lithium-ion cells and batteries as cargo on passenger aircraft
  • Limiting state-of-charge to 30%
  • Limiting the use of alternate provisions for small cells or batteries by air

EPA’s Electronic Hazardous Waste Manifest System — Roll-out to begin 06/2018. The Hazardous Waste Manifest is a shipping paper required for the transport of hazardous waste, and hazardous waste is regulated in transport by US DOT. While this rulemaking has implications across various industries, here are the consequences specific to hazmat shippers:

  • The new e-Manifest system will be rolled out on/by June 30th. The EPA plans to utilize the e-Manifest to collect domestic hazardous waste manifests and domestic shipments of State-only regulated hazardous wastes.
  • The e-Manifest system will be funded via user fees for the treatment, storage, and disposal facilities and State-only waste receiving facilities.

Doing your due diligence now can prevent a disaster, or hefty fine, later.

Winemakers Share Mechanization Experiences

February 13th, 2018 by Jason Snow

Filed under: Skolnik Newsletter, Wine

In the most recent edition of Wines and Vines, we learn that the availability of labor is a problem that’s going to continue, according to Keith Striegler, who moderated a session about winemaker experiences with vineyard mechanization during the recent Unified Wine & Grape Symposium in Sacramento. Striegler, grower outreach specialist for E. & J. Gallo Winery, noted in his introduction that more vineyard operations and practices are being mechanized, and mechanized pruning, shoot thinning and leaf removal change vineyard appearance. “When you make a change in the vineyard,” he said, “you have to have a buy-in by the winemakers in the winery, or you won’t get very far.” He then introduced the four panelists, who came from different regions and grow grapes for wines with different price points. Andrew Meggitt, winemaker, vineyard manager and co-owner of St. James Winery in St. James, Mo., discussed how St. James got into mechanization. When Meggitt first arrived at St. James from New Zealand in 2002, the winery produced 60,000 cases. Today, it is the largest winery in Missouri, farming 185 acres and producing 250,000 cases, with 65% of the grapes grown on St. James’ property. The winery plans to plant an additional 55 acres this year and another 50 acres in the two succeeding years. St. James Winery began a mechanization experiment in 2004 that lasted until 2009 using side-by-side rows in a block of Chardonel grapes. Meggitt reported that initially they found some variation in the fruit, but in 2010, the vineyard crew began doing a follow-up by hand to the mechanized pruning. “That cleaned up and opened up the canopy,” he said. “The ripening zone is more even.” In 2012, the winery made the decision to convert their entire vineyard property to mechanization for four reasons: lack of labor, increased efficiency, improved fruit quality and improved fruit consistency. “We couldn’t find labor,” Meggitt stated. “Mechanization improved the timing of vineyard operations—for pruning, bud rubbing, hedging, leaf removal, shoot thinning and positioning, cluster thinning and harvesting. Our spray bill dropped 30%, because we were getting light into the canopy, and that helped with the presence of all the diseases.” All the grapes used by the winery—whether grown in Missouri, Arkansas or Michigan—are grown in mechanically manipulated vineyards. “We’re growing flavors in the vineyard and producing higher margin wines, but we’re still learning how to do this. We’ll improve. Technology will improve,” Meggitt said. “We’ve improved the bottom line for the vineyard; that wasn’t our goal, but it helps.” Check out our full line of stainless steel wine barrels.