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

Posts Tagged ‘UN’

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.

Secondary Spill Containment: The Power of Prevention

May 1st, 2017 by Natalie Mueller

Filed under: HazMat, Safety

Containing and transporting hazardous materials or potentially dangerous goods is not a task to be taken lightly. The DOT, UN and EPA all have their own specific regulations regarding the avoidance and management of hazmat leaks and spills and at Skolnik, we strive to prepare businesses and shippers with the tools they need to maintain compliance and keep everyone safe. A solid plan and preparation is the best defense against a potential spill. The EPA calls such planning SPCC, and while it is specifically written with oil spills in mind, we think it holds several important lessons and tips for the handling of any dangerous good.

What does SPCC mean?

SPCC stands for Spill Prevention, Control and Countermeasures and it is a key component of the EPA’s oil spill prevention program. Essentially, an SPCC plan is a prevention plan for oil spills and leaks related to non-transportation related on or offshore oil operations.

Prevention is Key

While the EPA also requires oil operations to have a facilities response plan in place – the first step to solving a disaster such as an oil spill is to avoid it all together.

When handling dangerous goods of any kind, it is always better to be safe than sorry. Hazardous materials pose a grave threat to your employees, facility, community and/or the environment as a whole. No matter how careful you are in your operations, there is always a risk of a spill or leak. That’s where an SPCC plan comes in — as a Plan B in case all of your other careful planning has failed you.

In the business of transporting and storing hazardous materials, the most common and trusted form of SPCC are drum spill containers, or secondary spill containers.

Drum Spill Containers / Secondary Spill Containers

Drum spill containers are containers used in the event of an industrial hazardous or chemical spill. All Skolnik steel spill containers are suitable for clean up use or as secondary containment. Secondary spill containers are used either in response to an already leaking package,  in which case the leaking package will be contained in the secondary spill drum, thus mitigating the dangers of the leak; or as a preventative measure, in which case a non-leaking container holding hazardous materials is sealed within a secondary spill container for transportation and storage as an extra safety measure.

Secondary containment requirements are addressed by the Environmental Protection Agency (EPA) through the Resource Conservation and Recovery Act (RCRA) contained in title 40 of the Code of Federal Regulations (CFR) part 264, the 2006 Uniform Fire Code (UFC) in standard 60.3.2.8.3 and in the 2012 International Fire Code (IFC) in 5004.2.

Keeping up with Compliance: UN Certified Packaging

March 24th, 2017 by Natalie Mueller

Filed under: DOT/UN

You are probably already a safe, savvy and compliant business, but sometimes even businesses who follow UN and DOT regulations don’t fully understand them. The shipping and storage industry is heavily regulated — especially when it comes to handling hazardous materials or consumer goods such as pharmaceuticals or food and beverage. All of these rules and regulations have been put in place to protect transportation workers, the environment and the population. But, when you purchase UN certified packaging, what exactly does that mean?

The Manufacturer

Let us break it down for you. When buying a UN certified drum, the entire design of the drum, and all of its components is defined by the test samples. Each element — heads, ring, gasket, bolt, nut, plugs — must meet UN specified requirements. If even one of these components, or the design of the drum itself, doesn’t measure up, the drum is not UN compliant. At Skolnik, we

The initial onus for meeting UN standards is on the manufacturer, but once a UN certified package leaves our hands, it is up the filler to maintain compliance.

The Filler

Users cannot alter or exchange any of these components without it impacting the ability for the drum to perform as tested and certified.

If you were to purchase a UN certified drum with a nut and bolt style closure, but later swap that closure for a Leverlock, this would void the UN certification. At this stage in the container’s lifecycle, it is the fillers responsibility to adhere to UN regulations. If replacement parts are needed, fillers must make sure that they get original components form the original manufacturer that continue to meet the test criteria of that specific drum.

Make sure you always follow Skolnik’s Closure Instructions to verify a proper closure before passing the buck to your shipper.

The Shipper

Once a drum is filled, compliance with the UN certification is the responsibility of the shipper. It is up to the shipper to read the UN code and ensure the container is safely stored or shipped according to its contents.

Remember, no matter where you are in the journey of a container, non-compliance comes with a hefty fine. Fines for non-compliant shipments, of dangerous goods especially, are getting larger and more frequent. For the sake of your employees, facility and community, please keep an eye on evolving regulations and restrictions to ensure your UN certified packaging maintains compliance at every stage.