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

Archive for the ‘DOT/UN’ Category

No Torque Wrench, No Compliance!

May 29th, 2018 by Howard Skolnik

Filed under: DOT/UN, Skolnik Newsletter

By now, most shippers of dangerous goods know that following Closure Instructions for UN certified packagings is a must in order to have a compliant package. Having a non-compliant package, one that is not closed in accordance with the Closure Instruction, can put the shipper at risk for sizeable fines from the US-DOT. One of the steps in the Closure Process of a Salvage Drum or any Open Head, Bolt Ring style steel drum, is to:

TIGHTEN THE BOLT — with a calibrated torque wrench while using downward pressure on the cover and hammering the outside of the ring with a non-sparking dead-blow mallet to further seat the ring. Continue tightening and hammering the ring until the torque stabilizes at 55 – 60 ft-lbs and does not decrease when further hammering on the ring circumference is performed. Ring ends must not touch. (Effective 25 September, 2006 and in accordance with CFR 178.2(c), we have revised this procedure to use torque as the most effective closure requirement.

With a specific torque range specified, the shipper must be able to confirm that the closure meets this requirement. Closure without a calibrated torque wrench would result in a non-compliant package (unless the shipper has an alternate means to confirm the torque). When DOT inspectors visit shipper facilities, they will ensure that packaging manufacturers, fillers and shippers comply with Performance Oriented Packaging requirements specific to each packaging manufacturer. To confirm the measured torque, DOT Inspectors will expect shippers to have a recently calibrated Torque Wrench, and calibration certification in use when closing drums prior to shipment.

If a shipper chooses not to use a Torque Wrench, a Level-Lock Closure Ring is an alternative closure option. The Lever-Lock Ring does not require a Torque Wrench for a compliant closure.

Click here to see the written and video instructions of the Skolnik Closure Instructions for the Bolt and Lever-Lock Rings.

What’s that embossment mean??

May 22nd, 2018 by Howard Skolnik

Filed under: DOT/UN, Skolnik Newsletter

When a packaging has passed its performance test criteria, markings indicate the performance rating and test information specific to the certification test. This information must be applied in accordance with CFR 178.3(a)(3). For drums over 100 Litres (26 US Gallons) there are a number of ways that the marking can be applied including stamping, embossing, burning and printing and there must be one complete set of durable marks on the side or non-removable top head, and a second partial mark embossed permanently on the bottom head. The purpose of having the two marks is that once filled, the drum will sit, primarily, on its bottom head, and the UN test information will be readily viewable for the user at the side or top mark. The permanent partial bottom mark must conform to the application options indicated earlier. However, the side or top mark is required to be durable rather than permanent. Therefore, it is common and acceptable for the durable mark to be printed on the drum, or on a self adhesive label which is attached to the side of the drum. The characters on the label and the permanent embossment are subject to the size and sequence requirements as specified in 178.3(4) and 178.503(a)(1) through (a)(6) and (a)(9)(i).

Skolnik.com offers a unique breakdown of the individual marks by drum style. Click any of these links to understand the marking code:

The History of Hazmat and Dangerous Goods Packaging

May 3rd, 2018 by Natalie Mueller

Filed under: DOT/UN, HazMat

If you work in the packaging and transportation industries, there’s a good chance that you come across dangerous goods regularly. If you do, then you also come across the term ‘hazmat’. Now, it’s not hard to understand that the two are connected, but what are those connections exactly? What does hazmat have to do with dangerous goods packaging, and just who establishes the rules behind it all?

First, a quick definition. In the United States, the official term for dangerous goods is hazardous materials, which leads to the portmanteau hazmat. Pretty logical, but also easy to take for granted if it’s just another term in the day-to-day sea of acronyms and abbreviations.

Dangerous goods, and in turn hazmat, is a broad umbrella term that encompasses materials that are radioactive, flammable, explosive, corrosive, oxidizing, asphyxiating, biohazardous, toxic, pathogenic, or allergenic. Also included are physical conditions such as compressed gases and liquids or hot materials, and all goods containing such materials or chemicals, or that may have other characteristics that render them hazardous in specific circumstances.

Oversimplified: anything that can hurt a human.

 

Hazmat Regulation in The United States

With such an intimidating list of dangers under its purview, you would think that protection from dangerous goods has been a high priority for our government as long as possible. But, the DOT, EPA and OSHA, three of the most crucial agencies for regulating the safe handling of hazardous materials in the U.S. weren’t even formed until the late 1960s and 1970s.

Then, it was only in 2004 that the Department of Transportation created the Pipeline and Hazardous Materials Safety Administration (PHMSA), which is the agency directly in charge of developing and enforcing regulations in relation to hazmat transportation. Previously, PHMSA’s hazmat and pipeline safety programs were housed within the Transportation Department’s Research and Special Programs Administration (RSPA).

Hazmat Regulation Abroad

Regulators at the global level were a little faster to act. The United Nations Economic and Social Council (ECOSOC)’s publication of the first version of The UN Recommendations on the Transport of Dangerous Goods occurred in 1956. While it isn’t obligatory or legally binding on individual countries, this is the guiding document when it comes the establishing procedures regarding hazmat shipping. For example, all Skolnik barrels that bear a UN certification have been produced to the standards established by the most current version of these recommendations.   

The other crucial contribution to hazmat handling that the UN provides is the Globally Harmonized System of Classification and Labeling of Chemicals, developed in 1992. This is the set of rules that standardized the labeling of hazmat across borders, and is why we use the color coded diamond-shaped pictograms to designate which hazards are in what package.

Further Hazmat Regulatory Bodies

Along with these major organizations, there are plenty of smaller, more specific groups that have their eyes set on specific topics, such as the International Air Transport Association, the International Maritime Organization and the Intergovernmental Organisation for International Carriage by Rail. These are just some of the groups who, as each name suggests, focus on their individual priorities and establish rules and regulations that are adopted, inspire and influence how we handle hazmat here in the states and abroad.


Whether you interact with dangerous goods daily or once in a blue moon, it’s important to not only be able to handle the immediate task of safely storing and transporting these goods, but to know where they fit in larger scheme. If you don’t know why you’re labeling a barrel as hazardous, then it’s easy to make a mistake, and there is little room for error when dealing with hazmat storage and transportation. Luckily, there are plenty of resources for any question you may have regarding hazmat and dangerous goods packaging. All of these organizations have multiple resources you can explore, and if it’s barrel-related, chances are we here at Skolnik can help out too.

90-Day Waiver for ELD for Transporters of Agricultural Commodities

April 17th, 2018 by Howard Skolnik

Filed under: DOT/UN, Safety, Skolnik Newsletter

The U.S. Department of Transportation’s Federal Motor Carrier Safety Administration (FMCSA) announced on March 19, 2018, additional steps to address the unique needs of the country’s agriculture industries and provided further guidance to assist in the effective implementation of the Congressionally-mandated electronic logging device (ELD) rule without impeding commerce or safety. The Agency is announced an additional 90-day temporary waiver from the ELD rule for agriculture related transportation. Additionally, during this time period, FMCSA will publish final guidance on both the agricultural 150 air-mile hours-of-service exemption and personal conveyance. FMCSA will continue its outreach to provide assistance to the agricultural industry and community regarding the ELD rule.
Since December 2017, roadside compliance with the hours-of-service record-keeping requirements, including the ELD rule, has been steadily increasing, with roadside compliance reaching a high of 96% in the most recent available data. There are over 330 separate self-certified devices listed on the registration list.
Beginning April 1, 2018 full enforcement of the ELD rule begins. Carriers subject to Federal Motor Carrier Safety Regulations (FMCSRs) that do not have an ELD when required will be placed out-of-service. The driver will remain out-of-service for 10 hours in accordance with the Commercial Vehicle Safety Alliance (CVSA) criteria. At that point, to facilitate compliance, the driver will be allowed to travel to the next scheduled stop and should not be dispatched again without an ELD. If the driver is dispatched again without an ELD, the motor carrier will be subject to further enforcement action. Read the complete FMCSA action here.