Last month, the Final Rule for HM-189Y included a number of editorial and error corrections. Included in these was the addition of two semi-colons and a word correction in 49CFR 173.3 (c) Addressing Salvage Drums. The insertions further refine the distinct circumstances that permit the use of Salvage Drums. The modified text defines the use of Salvage Drums as: “Packages of hazardous materials that are damaged, defective, or leaking; packages found to be not conforming to the requirements of this subchapter after having been placed in transportation; and, hazardous materials that have spilled or leaked may be placed in a metal or plastic removable head salvage drum that is compatible with the lading and shipped for repackaging or disposal under the following conditions:…” Correction was needed to clarify that salvage drums could be used prior to, during and post transportation. This revision was effective September 28th, 2005.
Drum It Up! Steel Drum Industry News, Trends, and Issues
Archive for 2005
In accordance with 49CFR 178.2(c), closure instructions are required to be supplied by manufacturers and distributors of all UN certified packagings. Responding to an inquiry from a filler who owns their IBC fleet, PHSMA applied the applicability of 178.2(c), for the return of empty, used, Intermediate Bulk Containers (IBC‘s). In their response, PHMSA stated that yes, per 178.2(c)(1), each person to whom a packaging is transferred must be notified of all requirements not met at the time of transfer and must receive written closure instructions. It is the responsibility of the manufacturer or other person certifying compliance with Part 178, and each subsequent distributor of the packaging, to provide the notification. The applicability of this interpretation to a third party sale of the IBC was not addressed. PHMSA’s response was a bit unclear, but they appear to be suggesting that it is good practice for all persons transferring IBC‘s (and other UN packagings) to a third-party, to include closure instructions.
Recently, I spoke to a customer about some of the specialized uses for our Carbon and Stainless Steel Drums. He was surprised to hear that our Carbon and Stainless Steel Drums are used in the nuclear, pharmaceutical, chemical and wine industries and that we offer over 250 drum design types that are UN Certified for Dangerous Goods. While we only make the drums and never fill them, we know that our drums will be used to transport many dangerous and toxic contents, including radioactive and nuclear waste. Therefore, marginal is not acceptable for a Skolnik container. We use premium components, which combine to make our products meet the highest standards of drum integrity. As a dangerous goods packaging manufacturer striving to reduce storage and transport risks, all Skolnik products are thicker, heavier and stronger than industry standards.
ATA, The American Trucking Association, and the entire trucking industry, is assessing the impact of the devastation caused by Hurricane Katrina on Gulf Coast states. Today, our concerns are what we can do to help save lives; ensure adequate food, water and medical supplies reach hurricane victims; and accelerate recovery effort in parts of Louisiana, Alabama, Mississippi and South Florida. ATA developed a Web page to help motor carriers participate effectively in the national response and assist truckers traveling in the affected areas in the conduct of their day-to-day business. Through a comprehensive set of verified links, visitors can access the latest information on road closures, fuel waivers, relief from hours of service, and other critical developments. New information will be posted as soon as it arrives, so please bookmark this page and check back often. (http://www.truckline.com/katrina).
Companies continue to be fined by PHMSA for failing to train their hazardous materials employees. In August 2005, fines to 26 companies totaled $146,761.00, many of which were for non-compliant to CFR 172.704, the HazMat training requirements. All employees who have any responsibility involving dangerous goods or hazardous materials must be trained. Employees are required to receive initial training within 90 days of initial employment and then every 3 years thereafter or sooner if major rule changes affect your company. If you are unsure about your training compliance, contact www.r-a-specialists.com or www.dgac.org for a list of training class options and locations.
Two weeks ago, I was planning to attend a conference on dangerous goods in New Orleans. Today, New Orleans, itself, suffers from dangerous goods contamination. We have all learned so much these past weeks about emergency preparedness, empathy,compassion and generosity. Our daily conversations include updates on what is needed and what is being done to help with this incredible tragedy. At Skolnik, we are responding in several ways. First, we have made financial contributions to a large charity that is actively involved in the rescue and rebuilding mission. Within a day of the hurricane, we received calls from distributors and end users warning us that dangerous goods containers would be needed for the clean-ups. To this, we pledged to give these requests preferential status and prepared our scheduling and production. Drums that are headed to the Gulf coast to capture stray containers of potentially dangerous goods, are now shipping out everyday. We know that we are at the beginning of a long recovery process that is going to take years. We plan to keep helping as needed to improve the lives of our family, friends and fellow Americans in the Gulf Coast.