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COSTHA Initiates Return Logistics Safety Program

August 13th, 2008 by Howard Skolnik

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

The returning of products to a retail facility, sales agency, distribution center or manufacturer is referred to as Reverse Logistics. Reasons for return may include, but are not limited to, product obsolescence, malfunction, or damage rendering the product unfit for use. The persons engaged in packaging the products for return or offering the shipments in reverse logistics may often be laymen, retail store clerks or others, not readily identifiable within the definition of a “hazmat employee” as codified with 49 CFR. The packagings used for reverse logistics shipments are often not the original packagings as offered by the manufacturer and may consist of any packaging materials convenient within that facility. Equipment powered by internal combustion engines may have been used by the consumer prior to return and may contain residual hazardous material fuels. Reactive hazardous materials may not be properly segregated within the packaging or within over-packs and cargo transport units. These shipments may be wrongfully, and illegally, offered as “non-declared” hazardous materials and could be transported by all modes of transportation, including aircraft. The Council on the Safe Transportation of Hazardous Articles has partnered with the DOT (PHMSA) to obtain vital industry input through organized workshops, discussion groups, meetings, and other forums in order to develop acceptable and reasonable standards for these reverse logistic shipments. The product of the partnership should provide an assessment of the magnitude of the issue, the systems and standards that could be implemented to rectify potential problems citing means and materials needed to control these risks.

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