SkolnikNews

DOT Inspectors Target Records Retention

MDick — Thu, 13 Nov 2008 00:32:14 +0000

As DOT inspectors continue to visit hazardous material container manufacturers and shippers, part of their inspection often includes a review of the documents on file. Documents pertaining to the UN test certification must be retained. Whether manufacturing a new or reconditioned container, or filling and shipping, the test log and report for each specific design type of container must be retained. In addition, all current reports must be held for at least two years after the end of the final production run of that design type. The test report must contain (at a minimum) the following information: 1) Name and address of the test facility; 2) Name and address of the applicant; 3) A unique test report identification; 4) Date of the test report; 5) Manufacturer of the packaging; 6) Description of the packaging design type (eg: dimensions, construction materials, closures, wall thicknesses, etc.) including methods of manufacture (eg: lap or butt welding, blow molding, etc.) and which may include photographs, drawings or videos; 7) Maximum capacity; 8) Characteristics of the test contents (eg: viscosity and relative density for liquids and particle size for solids; 9) Test descriptions and results; and 10) A signed report with the name and title of signatory. A test certification that does not include, at least, all of this information can be determined to be incomplete and non-compliant. Prevent a possible fine from DOT and verify that; 1) you have these documents on hand; 2) that they are current; and 3) that they are complete.

NMFC’s New Density Rules for Empty Drum Shipments

HSkolnik — Thu, 13 Nov 2008 00:30:05 +0000

In our October 2008 blog/Newsletter, we informed our readers that the rates charged for transporting empty (new) steel drums had increased due to reclassification by the Commodity Classification Standards Board (CCSB) of the National Motor Freight Classification (NMFC). As of August 23rd, 2008, drums that were formerly shipped under class 92.5 would now be shipped under class 150 or higher resulting in a substantial cost increase per unit. Last week, at the annual conference of the Reusable Industrial Packaging Association, Mr. Rick Rubin of Maxi Container, Inc. gave a thorough presentation on the pricing procedure, old and new, for the shipment of these empty containers. The presentation included freight class definitions, a review of the old rules (Section 52800) and a review of the new rules (Section 174610). The presentation also offers sample calculations for open head and closed head drums, with and without pallets. We believe that Rick’s presentation brings clarity to a rather complex specification and we invite you to see Rick’s presentation. You can link to it directly at: New Density Rules for Steel Drums. Note the recommendations at the end of the presentation. FAK rates (freight of all kinds) are available, in most cases, and should be negotiated as soon as possible.

Wine Drums Are Now Available With a Top-Fill Option

JSnow — Thu, 13 Nov 2008 00:26:49 +0000

Skolnik has augmented its wide range of stainless steel wine drums with the launch of our new Top-Fill Wine Drum. Designed specifically for horizontal or vertical storage, these new drums have the traditional Tri-Clover flange centered in the top head of the drum. This new fill location allows wineries increased processing and storage flexibility in the wine making process.The Top-Fill Wine Drum is available for our most popular sizes, including the 16, 30 and 55 gallon stainless steel drums. If you are planning to attend the upcoming Wine Symposium in Sacramento in January 2009, we will be displaying the Top-Fill Wine Drum at our exhibit booth. Hope to see you in January!

DOT Introduces New Package Validation Testing Program

HSkolnik — Wed, 15 Oct 2008 20:26:38 +0000

On September 25th, 2008, representatives from the DOT met for the second time with the Reusable Industrial Packaging Association, RIPA, and other packaging industry associations in order to address the issues relating to the LOGSA testing program at Tobyhanna. Present from PHMSA were Ted Willke, Associate Administrator, Rob Richard, Deputy Associate Administrator, Ryan Posten, Director of Hazardous Materials Enforcement, and several other upper level regulators from DOT. RIPA was represented by Paul Rankin, Calvin Lee, Howard Skolnik and CL Pettit. Other associations represented included The Plastic Drum Institute, The Plastic Shipping Container Institute and IPANA. The highlight of the meeting was Ryan Posten’s introductory presentation of the National Packaging Strategy Mission. Given the results of more than 10 years of in-field testing at the Tobyhanna laboratory, the new Packaging Strategy will change validation testing significantly. Rather than gathering random packagings in the field, DOT will go directly to packaging manufacturers for the selection of packagings to be tested, and manufacturers will have the option of performing the validation tests on their own premises, at a third party test lab, or at the LOGSA facility at Tobyhanna. The goal of the new strategy is to eliminate non-compliance of packagings, utilize uniform protocols and generate support for manufacturer’s quality programs. DOT will emphasize the selection of high risk packaging and all data gathered will be used to identify trends and prioritize risks. Posten announced that as of August 8th, 2008, the in-field DOT inspectors were informed of this new approach to packaging validation. Therefore, manufacturers and shippers can expect a DOT inspector to arrive at their facility, ask to see samples of packagings, test certifications and training documents. Ultimately, DOT can request that testing validation be performed in their presence. In the event of a successful test, the visit will be complete. If testing is not successful, DOT will work with the facility to identify potential reasons for failure and retest. It’s a step in the right direction for DOT and US packaging integrity.

Increased LTL Rates for Empty Steel Drums Is Now In Effect

DRicker — Wed, 15 Oct 2008 20:24:55 +0000

As of August 23rd, 2008, the rates charged for transporting empty (new) steel drums has increased due to reclassification by the Commodity Classification Standards Board (CCSB). Drums that were formerly shipped under class 92.5 may now be shipped under class 150 or higher. The reclassification study has been a work in progress for the last 5 years. Common carriers were complaining that their profits were being reduced by the introduction of lighter packagings. Indeed, steel drum metal thickness has seen reduced averages, as has plastic drums and IBC’s. Therefore, CCSB sought to re-level the classification rates based on these new packaging specifications. Currently, we believe that not all carriers have acted on this matter; however, several regional carriers have begun negotiations with their customers. Furthermore, existing FAK (Freight of All Kinds) rates may also be under negotiation. Apparently, the trucking industry is very competitive at this time and we advise our customers and shippers to actively negotiate these new rates as soon as possible.

Salvage Drum Definition Clarified by DOT

HSkolnik — Wed, 15 Oct 2008 20:23:32 +0000

Per CFR 173.3(c), Salvage Drums have long been used as overpacks for the efficient and effective transport of damaged, defective or leaking containers, irrespective of whether these packagings are discovered before or after having been placed in transportation. In 2005, the DOT expanded the Salvage Drum definition to include non-compliant packagings (contents in inappropriate packagings). The ultimate use of these overpacked drums is to proceed to the nearest appropriate disposal or repackaging facility. Salvage Drums are not to be used as a secondary container, or overpack, for a primary shipment. Recently, DOT commented that while it is their intent for these packagings to be used for damaged, defective, leaking or non-compliant packagings that have already entered transportation, it is also their intent to limit the use to when packagings are discovered to be non-conforming after having been placed in transportation.

Shippers of TIH (Poison Inhalation) Drums Should Re-Qualify Their Cap Seals

HSkolnik — Thu, 18 Sep 2008 05:54:52 +0000

At the request of a customer that ships materials poisonous by inhalation (TIH drums, formerly known as PIH), we have researched and learned that the performance criteria of cap seals on these steel drums needs to be qualified by each shipper, not the cap seal manufacturer. As required in 49CFR 173.226(b)(3)(iii), a cap seal is required to withstand 100 kPa as a primary seal – not in conjunction with the inner plug. There are two predominant manufacturers of these cap seals (Rieke and American Flange) and both are unwilling to issue performance certification for their cap seals as a primary seal. While they are offering a 100 kPa certification that includes the installed plug, this is not compliant with the CFR. While DOT is aware of this issue, we are suggesting to all TIH shippers that they perform their own performance test to certify that the cap seals, when installed as the primary seal, are able to meet the 100 kPa criteria. If inspected by DOT, failure to have this information documented could lead to a finding of non-compliance.

Higher Education Embraces Skolnik’s Stainless Steel Wine Drums

JSnow — Thu, 18 Sep 2008 05:54:00 +0000

More and more, universities with Viticulture and Enology Programs (the study of winemaking) are introducing the use of Stainless Steel Wine drums into their processing curriculum. As the popularity and use of stainless steel wine drums continues to grow, Enology professors recognize the importance of teaching their students how to incorporate the use of stainless steel drums into their wine making knowledge. Throughout this past year, Skolnik Industries has been active in assisting several universities with their wine making programs, supplying them with our full line of stainless steel wine drums, and helping them to better understand the performance properties of stainless steel. We have been pleased to hear back from many of these programs that the students are quick to absorb these new options. Furthermore, as they learn the fine art of wine making, the students appreciate the added properties that come with selecting stainless steel. We are always happy to speak with colleges and universities about their wine making programs and we now offer special pricing for university purchases that will be used in the training process.

Skolnik Joins in the Celebration of Global Quality!

MDick — Thu, 18 Sep 2008 05:53:01 +0000

On November 13th, 2008, Skolnik will join other manufactures around the world to celebrate World Quality Day. A chance for quality professionals and organizations to unite around the world and celebrate their achievements, World Quality Day helps to raise the consciousness of how quality approaches can make a tangible impact on business. Skolnik is a small business, independently owned and dependant on our Chicago manufacturing facility to “keep our customers happy.” We are considered to be a leader in the industrial container market as measured by our customer relationships and product dependability. At the core of our process, we have implemented a quality plan which requires us to meet our unique customer requirements - and to do so on time. Part of the celebration at Skolnik will include company-wide training in recent quality developments as well as identifying new quality opportunities to consider in the coming year. We take pride in our quality program and performance. It is this plan that helps us to meet the world class standards that benefit our customers and our employees.

Skolnik Hosts DOT/UN Testing Symposium

HSkolnik — Wed, 13 Aug 2008 13:14:01 +0000

Since the adoption of performance oriented packaging standards (POPS) more than 10 years ago, the US has been the only country to allow manufacturers and reconditioners of UN certified packagings, to self-certify their containers. Taking the requirements from the Code of Federal Regulations (CFR49), there is no testing standard or protocol with which these tests are performed. Those performing the tests usually have no formal training other than past experience learned from another tester. The result has been that interpretations of the requirements can vary and performance of the tests are sometimes incomplete. At Skolnik, we believe that the establishment of a POPS Test training program will help new and ongoing packaging manufacturers to better understand the testing procedures and on July 23rd, 2008, we hosted a Testing Symposium in which 20 POPS Test specialists met to create a forum for beginning the training program (See Testing Symposium Pictures). In addition, Haldis Fearn of HMF2 attended to assess the knowledge and experience of the testing specialists with the intent to create a training curriculum. In addition to reviewing the regulatory requirements for the stack, drop, leakproofness and hydrostatic pressure test, attendees were able to witness the preparation and actual performance of each test. The day proved to be successful and all the attendee’s requested that we repeat this event, at least, annually. If you are interested in attending the next Symposium, please contact me directly to be added to our participant list.