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Archive for the ‘Associations’ Category

DOT, Really???

June 20th, 2013 by Howard Skolnik

Filed under: Associations, DOT/UN, HazMat, Industry News

At a Packaging Roundtable meeting at the recent annual Council on the Safe Transport of Hazardous Articles (COSTHA) conference in San Diego, members were discussing issues relative to the DOT’s Test Validation Program, aka Tobyhanna. The DOT submits packagings that they purchase in the public domain and validate, or retest, the packagings performance to the UN markings on the specific package. Over the years, there have been countless comments regarding inconsistent testing procedures and excessive testing demands — sometimes beyond the requirements of the Code of Federal Regulations, but a story that I heard at the Packaging Roundtable takes 1st place among the Closure Instruction requirements that, in my opinion, are meaningless to the packaging’s performance and the safe transport of dangerous goods.

A UN certified cardboard box was purchased and sent for testing at Tobyhanna. As a part of the pretest qualification, the weight of the box was checked against the weight of the Performance Test documentation and a discrepancy of a few grams was found. What is curious about this is that the CFR calls out that the metric weight of the box, in kilograms, would have to be identified, however, in this case, they were looking for grams of difference. After reviewing the construction of the box, the test lab determined that the Closure Instructions did not specify the amount and dimensions of tape used for compliant closure and that if they specified the length and width of the tape used to close the box, this piece of tape would make up for the missing grams. To measure the weight, they took a piece of the specified tape, crumpled it into a ball, and weighed it. The final determination was that the Closure Instructions for the box had to be modified to specify the tape requirement for compliant closure. I am not aware if the box manufacturer was dealt a fine for the violation.

Bring your issue to one of our Packaging Roundtable’s

November 18th, 2012 by Howard Skolnik

Filed under: Associations, HazMat, Industry News

In response to discussions held during the Strategic Planning meetings, the Council on the Safe Transport of Hazardous Articles (COSTHA) members have asked to have a Packaging Roundtable established. The purpose of the group is to allow package testing companies, manufacturers and distributors to meet in an informal setting to discuss current issues, regulations, questions and a broad area of concerns. Members who purchase and use packaging have also expressed interest in having an opportunity to interact with such a group to clarify regulatory requirements, best management practices and other subjects. Skolnik is a participant in the Roundtable. In addition to the COSTHA Roundtable, Skolnik also participates in the Dangerous Goods Advisory Council (DGAC) Packaging Working Group as well in various topical groups in the Reusable Industrial Packaging Association (RIPA). As a friend or customer of Skolnik, let us know if you have packaging or regulatory issues, concerns or questions, which affect your compliance with the Code of Federal Regulations (CFR) or United Nations (UN) packagings. These groups provide the opportunity for companies to meet one-on-one, or in a small group environment with regulators and other hazmat professionals to discuss packaging related issues. Please let us know if you currently have any issues that need special attention.

Thanks Labelmaster for DGIS VII !!!

September 8th, 2012 by Howard Skolnik

Filed under: Associations, Industry News

For the 7th year, this past week, Labelmaster hosted the Dangerous Goods Instructors Symposium in Chicago. The Symposium is the only gathering of dangerous goods trainers designed to elevate the competency and effectiveness of dangerous goods education. The result of these training efforts is to ultimately save lives. The Symposium attracted about 150 hazmat instructors and regulators from all parts of the world and focused on the need to improve training of all those participating in the transport of dangerous goods. Some topics presented included Lithium Battery regulatory changes, Training Competencies, What’s The Worst That Can Happen When We Take (HazMat) Short Cuts, and PHMSA presented a special permit update. Training workshops focused on Trainer Personality Profiles, Active Learning, Emergency Response in Action at the Union Pacific, Taking the Mystery Out of Explosives and Regulatory Quirks. Some of the presenters included Geoff Leach of the UK CAA, Peter Mackay of Hazardous Cargo Bulletin, Gene Sanders of WE Train, Jay Johnson of Inmark, Vaughn Arthur of DGAC, Ajay Pande of FIATA, Ben Barrett of SAMMI, Laura Denk of eChoice Innovations. The Symposium has become the most acclaimed training event of the year and I would like to thank the Labelmaster staff including Dwight Curtis, Jeanne Zmich, Rhonda Jessop, Nancy Wingert, Neil McCulloch, Bob Richard, Tracie Cady, Pia Jalla, Christine Sandlass, Estuardo Sanchez and Jason Schellenberg for hosting this significant safety event.

DGAC Creates Packaging Working Group

August 10th, 2012 by Howard Skolnik

Filed under: Associations, HazMat

A working group has been established by the Dangerous Goods Advisory Council (DGAC) to examine packaging testing issues. The group is primarily concerned about container testing by DOT at its Tobyhanna test lab. Group members include packaging manufacturers and shippers of hazardous materials. The Group plans to identify a strategy for working with DOT to use the information gathered at Tobyhanna as a research tool to improve the safety of packaging. The group will review data compiled by DOT since it initiated container testing at Tobyhanna more than a decade ago. They will also examine why packaging design type tests performed successfully at a manufacturers’ locations often result in failures at Tobyhanna. In addition, the Group will review the accuracy of the data obtained from Tobyhanna and posted on the PHMSA website. DGAC also wants to establish a forum for information exchange among and between companies that perform testing, and shippers that use hazmat packaging domestically and internationally. DGAC plans to open and maintain a dialogue with PHMSA on packaging testing issues to ensure all parties fully understand the purpose of Tobyhanna testing and the value of the data published by the Agency.

As a founding member of this Working Group, I believe the DGAC effort will compliment the work that other organizations have done on this issue for more than 15 years. It is critical that DOT recognize that a wide range of packaging producers and shippers are concerned that the Tobyhanna test results do not reflect the real-world performance experience of hazmat packagings (e.g. steel drums). In-field transport of our packagings is successful globally and we want to understand why DOT is focusing on a problem that, statistically, does not exist.