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

Verify that Closure Instructions are On-Hand and In-Use

July 14th, 2009 by Howard Skolnik

Filed under: DOT/UN, HazMat

By now, most of our Newsletter readers know that for all HazMat packagings, the packaging manufacturer is required by CFR 178.2(c) to deliver Closure Instructions with each package sold. Recently, a customer informed us that one of their other suppliers for a hazmat packaging refused to give them a Closure Instruction and UN Certification, claiming it was “proprietary information.” This is completely untrue, and if the shipper chooses to close his/her package without the specific Closure Instruction from the manufacturer, then the shipper would be liable for a DOT non-compliance violation. Closure Instructions for steel drums require that the closing of a steel drum be translated into a technical instruction. These instructions are written without any DOT guidelines but must indicate the measures necessary in order to properly secure a package for transport. These measures may include; specially calibrated tools; measurements; torque; and other familiar references. Recently, the DOT did state that they expect Closure Instructions to include some reference to torque capacities. Be sure that your Steel Drum supplier is providing Closure Instructions that meet the requirements of CFR 178.2(c) and that you have the tools on hand necessary to comply with these instructions. Also, verify that the Closure Instructions are being followed at each shipping location and that correct, and calibrated tools, which are current, are being used. Click here to verify that you have current SKOLNIK Closure Instructions for all your SKOLNIK containers.

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