Skolnik

The winds of change are blowing through DOT’s Pipeline and Hazardous Materials Safety Administration (PHMSA). At a recent Council of Safe Transportation of Hazardous Articles (COSTHA) conference in San Diego, DOT was well represented by Bill Schoonover, Deputy Associate Administrator of Field Operations; Ryan Paquet, Director of Approvals and Permits;  Charles Betts, Director of Standards and Rulemaking and a Skype appearance by PHMSA’s Associate Administrator,  Dr. Magdy El Sibaie. In their numerous presentations, all four representatives stressed that DOT was focused on their new mission, ”To protect people and the environment from the risks inherent in the transportation of hazardous materials.”

They stated that DOT is now looking at risk analysis to determine the needs of regulatory direction, as well as adoption of standards and new policies. They have had to rethink how they will achieve this mission. One example of the emphasis of their focus has been seen by the increased number and speed with which special permits are now being approved. Only a few years ago, these permits ground to a halt and strangled many viable shipments. Another refocus of PHMSA has been for the purpose of their validation testing lab, LOGSA (aka: Tobyhanna).

With a reduction in Federal funding, Tobyhanna has been moved from Enforcement to Research with the mission to pair in-field risk with testing validation of hazardous materials packagings. Under enforcement, packagings that were sent to Tobyhanna validated the packaging marks and the end result was either a pass, or fine for failure of any aspect of the performance tests. The information learned from the wealth of these tests was not shared with industry to improve safety. Under the new policy, DOT will establish a “risk analysis” formula for selecting packagings which indicate an elevated in-field risk, and these packagings will then be validated. After testing, DOT will present, online, the testing standards, process, results and protocol that will be useful in understanding actual packaging performance. These results will allow industry to understand and benefit from the test process, thus meeting DOT’s  mission to improve public safety.  Furthermore, even though fines for failure will still exist, PHMSA will work closely with industry to reach the objective of the mission which is to link testing to improving public safety. It will be a goal of the PHMSA administrators to be able to state that “packagings tested at the LOGSA test lab are successfully passing at a rate of 100%!”

In order for a drum to be compliant with UN certification, each packaging must be embossed and durably marked with a proper UN nomenclature sequence. Though inconsequential to the test performance of a package, DOT markings are critical for package identification and regulation. For the most part US packaging manufacturers are putting the required information on packaging in both durable and embossed formats, but some minor errors have surfaced. For instance, for the UN emblem, the letters “un” must appear vertically in lower case – upper case letters are non-compliant. If the emblem is not used, then the upper case letters positioned horizontally are required. Also, for packagings that have more than one certification, some manufacturers were noting the year of manufacture only once, when this information would have to be a part of each certified marking. CFR 178.503 specifically states the sequence for marking information. While the DOT does not consider these non-compliance issues to be a safety issue, it is best that all manufacturers and fillers verify that the markings on their packagings are compliant. To better understand the marking sequence, we have prepared 4 examples of UN markings with a break out of the meaning of each character. Click here to see the UN markings.