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.
Drum It Up! Steel Drum Industry News, Trends, and Issues
Archive for 2004
Our customers are frequently asking this question. While most of the open head drums manufactured by Skolnik are dual tested and marked for both liquids and solids, the closed head drums are only tested and marked for liquids. However, in some cases, a product can be a liquid when filled and solidify during transport. In this case, some inspectors have declared that as solids, they should be in a solids container. Thus the shipment is declared non-compliant and refused. In CFR 49 173.24a(b)(3), DOT does permit the use of a liquids container for a solid, and offers an equivalent calculation to achieve container maximum weight for single or composite packagings that are Packing Group I, II or III. If a shipper can comply with this calculation and indicate that the liquids container does comply with 173.24a(b)(3), then shipping the solid in the liquid marked container is compliant. Of course, the dual marked container is still preferable.
Used for safe transport or disposal of damaged, leaking or non-conforming containers (CFR 173.3), there is no time limit for the use of a Salvage Drum as long as it is fulfilling the definition of its use. Most frequently, Salvage Drums prove to be a safe, easy-to-use and inexpensive way to transport a damaged, leaking or non-confirming container to the nearest disposal or repackaging location. Should the contents pose a hazard to the environment, then the EPA should be consulted for guidance on the shipping paper requirements.
Labelmaster® Academy will host a 1 hour on-line ‘webinar’ on cargo security on September 29, 2004 at 11 am CST. The webinar will cover the background of cargo security, security-related regulatory requirements and cargo security itself. Hosted by Brad Penneau, this webinar will provide strategies that can help you lower annual loss;protect against terrorism; learn industry “best practices” strategies on security; and provide advice on how to comply with the new hazardous materials security requirements. The cost for attending this on-line seminar is $99.00 and you can register at https://www.labelmaster.com/shop/training or by calling 773.478.0900.
More than one-third of the Department‘s enforcement actions pertaining to violations of the hazardous materials transportation regulations involve the failure of hazmat employers to provide training or maintain test records. In most cases violations are attributed to failure to provide function specific training. For example, an investigator questions incorrect entries on a shipping paper prepared by a hazmat employee who responds that he was not instructed, nor tested, by his hazmat employer regarding the preparation of shipping papers. You should determine if the safety training is appropriate to your business activity. Hazmat training is a critical element to the future of your business and not something that should be overlooked. Training information can be found at: http://hazmat.dot.gov/training.htm or by calling the Office of Hazardous Materials Initiatives and Training at 202.366.4900.
Salvage Drums have long been used for quick, easy and cost efficient remediation of damaged, leaking (and now non-compliant) drums. Originally designed to be greater than, or equal to, the construction specifics of the inner container, the POPS requirement was that the drum be at least a ‘Z’ (Packing Group III) solids container. Convinced that this was not an acceptable test for a Salvage Drum, on January 1st, 1998, the ’T’ Salvage Drum (1A2T) became the UN recommended salvage packaging for international shipments. The US-DOT also recognizes the ’T’ Salvage Drum for shipments within the US. Unlike the 49 CFR Salvage Drum requirement, the ’T’ Salvage Drum is generally an 85 US gallon capacity steel drum that, when filled with water, can be dropped 4 feet on its‘ most critical orientation, and not leak. This test is very severe for a steel container, but it illustrates the capabilities of the ’T’ Salvage Drum to be used for recovery missions. To find out more about ’T’ Salvage Drums, contact me or one of the Skolnik sales staff. We are fully trained in the aspects of these extraordinary drums.