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Industrial Packaging for Critical Contents

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

Posts Tagged ‘dot’

Overpack Salvage Drums not Recommended for Primary Shipment

June 25th, 2018 by Natalie Mueller

Filed under: Salvage Drum

Salvage drums have long been used as overpacks for the efficient and effective transport of damaged, defective or leaking containers. However, according to the DOT, salvage drums are NOT to be used as a secondary container, or overpack, for a primary shipment.

Rather, an overpack salvage drum should only be used for damaged, defective, leaking or non-compliant packagings that are discovered after having been placed in transportation.

In 1998, the ‘T’ Salvage drum became the United Nations’ recommended salvage packaging for international use. It is most commonly an 85 US gallon capacity. To bear the UN certification, overpack salvage drums are rigorously tested. They must be able to be dropped 1.2 meters (4 feet) on its most critical orientation without leaking and pass a 30 kPa overall Leakproofness Test. However, while they are certified to hold non-compliant packages in transport, the DOT recommends that, once overpacked in a salvage drum, a non-compliant container should be routed to a facility for disposal or re-containment. You can never be too careful.

And remember, traditional overpack drums are designed to protect non-leaking containers or to be used in a combination pack, they are not certified to hold damaged/non-compliant containers.

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.

2018 New Hazmat Rules At-A-Glance

February 22nd, 2018 by Natalie Mueller

Filed under: DOT/UN, HazMat, Industry News

They say the only thing constant is change and that couldn’t ring more true for those of us in the dangerous goods business. As the transportation, manufacturing, chemical and hazmat industries all keep evolving, so too do the regulations that govern them. At Skolnik, we do our due diligence to ensure all of our products meet, if not exceed, the hefty regulatory standards they face. Part of that due diligence is staying on top of changes to the rules and regulations.

In 2018, a few new rules regarding hazmat containers and shipment will hit the books — here’s a quick look at what those regulations, some of which have already taken effect.

Already in effect:

International Air Transport Associations Dangerous Goods Regulations (IATA DGR), 59th Edition – In effect as of 01/01/2018

Changes include:

  • Stricter requirements regarding air-shipment of lithium batteries

  • A re-organized list of Class 9 materials (see Subsection 3.9.1)

  • A new list forecasting changes for air shippers in 2019 (Appenix I).

Furthermore, IATA has already published an addendum to this year’s DGR that impacts air shippers and airline passengers alike, so look for that as well.

2016 International Maritime Dangerous Goods Code (IMDG Code) — Updates in effect as of 01/01/2018

Reinforces updates that were made in the 2016 edition. Compliance to these updates was voluntary last year, as of this year they are officially mandatory.

Rules include:

  • New dangerous goods marking and labeling criteria

  • New packing instructions for certain shipments of engines, lithium batteries and aerosols

  • Adjustments to the IMDG Code Dangerous Goods list

Coming soon:

Enhanced Safety Provisions for Lithium Batteries by Air (RIN 2137-AF20)  — Expected 02/2018

This Interim Final Rule will harmonize the 49 CFR hazmat regulations with evolving international standards for the air shipment of lithium batteries. International requirements already in effect under the latest IATA DGR will be adopted into 49 CFR.

Rules include:

  • Prohibiting lithium-ion cells and batteries as cargo on passenger aircraft

  • Limiting state-of-charge to 30%

  • Limiting the use of alternate provisions for small cells or batteries by air

Response to Industry Petitions (RIN 2137-AF09) — Expected 02/2018

Currently, parties must petition US DOT to amend, remove or add hazmat regulations to enhance safety/efficiency for shippers and carriers. In 2018, the Pipeline and Hazardous Materials Safety Administration (PHMSA) plans to address 19 of these petitions. This response will likely include new amendments and rules.

 

Miscellaneous Amendments Pertaining to DOT Specification Cylinders (RIN 2137-AE80) — Expected 04/2018

Likewise, DOT will address various petitions from industry stakeholders. These petitions pertain to the manufacture, maintenance and use of DOT specification cylinders. This ruling will incorporate two existing hazmat special permits into the 49 CFR Hazardous Materials Regulations (HMR)

 

EPA’s Electronic Hazardous Waste Manifest System — Roll-out to begin 06/2018

The Hazardous Waste Manifest is a shipping paper required for the transport of hazardous waste, and hazardous waste is regulated in transport by US DOT. While this rulemaking has implications across various industries, here are the consequences specific to hazmat shippers:

The new e-Manifest system will be rolled out on/by June 30th. The EPA plans to utilize the e-Manifest to collect domestic hazardous waste manifests and domestic shipments of State-only regulated hazardous wastes. The e-Manifest system will be funded via user fees for the treatment, storage, and disposal facilities and State-only waste receiving facilities.

Oil Spill Response Plans for High-Hazard Flammable Trains (RIN 2137-AF08) — Expected 07/2018

A Final Rule from DOT to expand the applicability of oil spill response plans for trains transporting Class 3 flammable liquids in specific volumes and orientations across the train. This requirement will apply to High-Hazard Flammable Trains (HHFTs).

These are just the new hazmat rules that are already on the horizon. As always, Skolnik will continue to monitor future regulations or updates that may impact operations, shippers, brokers and carriers, and we encourage all other dangerous goods professionals to do the same.

Doing your due diligence now can prevent a disaster (or hefty fine) later.