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Drum It Up! Steel Drum Industry News, Trends, and Issues

Archive for the ‘DOT/UN’ Category

DOT Issues at Statement Regarding New ICAO Instructions

January 29th, 2019 by Howard Skolnik

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

The U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA) understands that many offerors and carriers of hazardous materials in international transport will soon be adhering to requirements in the internationally-adopted 2019-2020 International Civil Aviation Organization’s Technical Instructions for the Safe Transport of Dangerous Goods by Air (ICAO Technical Instructions) and Amendment 39-18 of the International Maritime Organization, International Maritime Dangerous Goods Code (IMDG Code). The Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) currently authorize offerors and carriers to use the 2017-2018 Edition of the ICAO Technical Instructions and Amendment 39-16 of the IMDG Code.

PHMSA gives notice that while it determines whether to adopt the 2019-2020 Edition of the ICAO Technical Instructions and Amendment 39-18 of the IMDG Code, it will not take enforcement action against any offeror or carrier who is using these standards when all or part of the transportation is by air with respect to the ICAO Technical Instructions, or all or part of the transportation is by vessel with respect to the IMDG Code. In addition, PHMSA will not take enforcement action against any offeror or carrier who offers or accepts, for domestic or international transportation by any mode, packages marked or labeled in accordance with these standards. This enforcement discretion will be exercised by the Federal Aviation Administration, the Federal Motor Carrier Safety Administration, the Federal Railroad Administration, the Pipeline and Hazardous Materials Safety Administration, and the United States Coast Guard.

This notice is limited to the use of the standards incorporated by reference in 49 CFR § 171. 7 ( t) and (v). Offerors and carriers must comply with all other obligations under the HMR and other applicable laws. This notice will remain in effect until rescinded or otherwise modified.

Do UN Steel Drums Expire?

December 25th, 2018 by Howard Skolnik

Filed under: DOT/UN, Skolnik Newsletter

It is important to know that once a certified UN steel drum is manufactured, it can be invalidated, but it never expires! What is critical is that the certification test report is valid when the drums are manufactured. Though certification on the steel drum does not expire, it can be deemed noncompliant if the components used in the drum are not as those specified in the Closure Instructions from the original steel drum manufacturer, or the most recent re-manufacturer.

To fully understand this distinction, drums that are regulated by the DOT, have to be manufactured within 12 months of the Performance Test Report date. If a specific drum is tested on Jan 1, 2018, a manufacturer can continue to manufacture that drum until Dec 31, 2018 under the conditions granted by the Performance Test Report. In order to continue the flow of production, a new replacement test, and Test Report, would have to be in force before Dec 31st 2018, and this would give certification to drum manufactured from the Test date as noted in the Report, for 1 year from that test date. Drums will then have a UN durable mark and permanent mark that indicate the year of manufacture. This is an example of a Performance Test Report.

Once a drum enters use and is in the field, there is no expiration date. However, the drum will always be subject to the closure instruction for that drum. Usually, closure instructions will include an inspection of the gasket or other critical components of the drum. It is the shippers responsibility to be sure that all components are in a like condition as when the drum was new. If DOT were to inspect a 10 year old drum and test it, they would expect it to perform to the original Test Report.
At Skolnik, we keep a list of all our testing expiration dates. This allows our customers to know that the drums they are using regularly have ongoing testing. www.skolnik.com/uncertifications

Check the “Hazmatt” Box!

September 25th, 2018 by Howard Skolnik

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

Many of the products that we use on a daily basis, including batteries, aerosol sprays, and adhesives, contain hazardous materials (hazmats). The U.S. Department of Transportation’s (DOT) hazmat regulations require that these products be properly classified, packaged, labeled, handled, and stowed for transportation over public right-of-way. This protects workers, emergency responders, and the general public from the risks associated with hazmat transportation. The US Dept of Transportation has introduced a new character, ‘HazMatt’, designed to help ‘reach the unreached’ who are unaware that they are shipping hazardous materials. Speaking at the recent Labelmaster DG Symposium, PHMSA’s Shane Kelley explained that all the modal agencies under DOT are working together to get the message out as widely as possible, particularly to those that do not normally receive the hazmat message. The project is ongoing — and is worth following at checkthebox.dot.gov.

Remember: If you ship products, it is your responsibility to know whether those products are hazmat, and to communicate their hazards appropriately, according to DOT’s hazmat regulations. Shipping a non-compliant hazmat can result in hefty fines from the DOT!

The Importance of Clarity: Overpack Drums vs. Salvage Drums

August 1st, 2018 by Natalie Mueller

Filed under: DOT/UN, Salvage Drum

We can’t overstate how important it is for everyone involved in the shipment or storage of materials to understand the requirements of the situation and materials. In our line of work, part of that is knowing the right drums are used when shipping materials in order to comply with safety standards. These safety standards are important for keeping people safe, but also for avoiding the penalties that come with using defective drums, or the wrong class of drum entirely.

In the past, there has been confusion among manufacturers, customers, and shippers about the difference between Overpack Drums and Salvage Drums. Due to a lack of clarity, and a industry wide game of telephone, Overpack Drums and Salvage Drums were thought of as the same exact products for a while. This, of course, leads to a whole array of problems. First of all, if you were to use an Overpack Drum to do the job of a Salvage Drum, your materials would not be secure. Second, that particular load would certainly not meet DOT or UN standards.

As you would guess, there is a marked difference between Salvage and Overpack. A difference that, while we are sure most everyone in this industry knows, bears repeating — which is why we revisit this topic regularly. Overpack drums are used to hold packages or materials that are still properly sealed and meet safety and shipping regulations on their own, and the drum is used to consolidate materials. Think of them as a second layer of protection, or a handy way to transport multi-pack items. Salvage drums are used to hold leaking, damaged or otherwise compromised and non-compliant packages.

Clarifying every detail of your materials or shipment is important to everyone involved. There are a laundry list of important regulations that protect us, and the environment, but without clarity and strong communication about standards and norms, it is incredibly difficult to follow them and maintain good, safe and compliant business practices.