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DOT Enhances Closure Instruction Requirements

October 5th, 2004 by Howard Skolnik

Filed under: DOT/UN, HazMat, Safety

On October 1, 2004, the new U.S. hazmat provisions issued as HM 215-E becameeffective. Per CFR49, 178.2(c), all shippers of hazardous materials are responsible for following the closure instructions that accompany all UN or DOT marked packagings.Closure instructions must now include any "procedures" used in assembling and closing the packaging for the "purpose of preventing leakage in transportation". An example would be using a mallet to better secure a ring. Also, DOT suggests that a container must be securely closed when filled and prior to transport, the shipper should check the tightness of closures to determine if the effects of heating, cooling or gasket relaxation have resulted in the need to tighten the closure. Closure instructions are NOT generic and must be current. Skolnik provides closure instructions for every product manufactured. If you need a current copy, please contact Customer Service, or download here.

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2 Responses

  1. In what part of the CFR49 says that ” a container must be securely closed when filled and prior to transport, the shipper should check the tightness of closures to determine if the effects of heating, cooling or gasket relaxation have resulted in the need to tighten the closure” ?

    Regards,

  2. HZSkolnik says:

    Per 49CFR 178.2(c)(1)(ii), A manufacturer or other person certifying compliance shall notify, in writing, each person to whom that packaging is transferred, with all requirements not met at the time of transfer and with information specifying the types and dimensions of the closures, including gaskets and any other components needed to ensure that the packaging is capable of successfully passing the applicable performance tests.

    Therefore, if the manufacturer believes that temperature variations would effect the closure integrity, this information would become a part of the manufacturer’s Closure Instruction.

    In the Skolnik Closure Instruction, http://www.skolnik.com/ClosureInstructions092506.pdf,
    we specify that temperature can effect the closure integrity and that closures need to be verified prior to shipment.

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