On September 25th, 2008, representatives from the DOT met for the second time with the Reusable Industrial Packaging Association, RIPA, and other packaging industry associations in order to address the issues relating to the LOGSA testing program at Tobyhanna. Present from PHMSA were Ted Willke, Associate Administrator, Rob Richard, Deputy Associate Administrator, Ryan Posten, Director of Hazardous Materials Enforcement, and several other upper level regulators from DOT. RIPA was represented by Paul Rankin, Calvin Lee, Howard Skolnik and CL Pettit. Other associations represented included The Plastic Drum Institute, The Plastic Shipping Container Institute and IPANA. The highlight of the meeting was Ryan Posten’s introductory presentation of the National Packaging Strategy Mission. Given the results of more than 10 years of in-field testing at the Tobyhanna laboratory, the new Packaging Strategy will change validation testing significantly. Rather than gathering random packagings in the field, DOT will go directly to packaging manufacturers for the selection of packagings to be tested, and manufacturers will have the option of performing the validation tests on their own premises, at a third party test lab, or at the LOGSA facility at Tobyhanna. The goal of the new strategy is to eliminate non-compliance of packagings, utilize uniform protocols and generate support for manufacturer’s quality programs. DOT will emphasize the selection of high risk packaging and all data gathered will be used to identify trends and prioritize risks. Posten announced that as of August 8th, 2008, the in-field DOT inspectors were informed of this new approach to packaging validation. Therefore, manufacturers and shippers can expect a DOT inspector to arrive at their facility, ask to see samples of packagings, test certifications and training documents. Ultimately, DOT can request that testing validation be performed in their presence. In the event of a successful test, the visit will be complete. If testing is not successful, DOT will work with the facility to identify potential reasons for failure and retest. It’s a step in the right direction for DOT and US packaging integrity.
Drum It Up! Steel Drum Industry News, Trends, and Issues
Archive for October, 2008
As of August 23rd, 2008, the rates charged for transporting empty (new) steel drums has increased due to reclassification by the Commodity Classification Standards Board (CCSB). Drums that were formerly shipped under class 92.5 may now be shipped under class 150 or higher. The reclassification study has been a work in progress for the last 5 years. Common carriers were complaining that their profits were being reduced by the introduction of lighter packagings. Indeed, steel drum metal thickness has seen reduced averages, as has plastic drums and IBC’s. Therefore, CCSB sought to re-level the classification rates based on these new packaging specifications. Currently, we believe that not all carriers have acted on this matter; however, several regional carriers have begun negotiations with their customers. Furthermore, existing FAK (Freight of All Kinds) rates may also be under negotiation. Apparently, the trucking industry is very competitive at this time and we advise our customers and shippers to actively negotiate these new rates as soon as possible.
Per CFR 173.3(c), Salvage Drums have long been used as overpacks for the efficient and effective transport of damaged, defective or leaking containers, irrespective of whether these packagings are discovered before or after having been placed in transportation. In 2005, the DOT expanded the Salvage Drum definition to include non-compliant packagings (contents in inappropriate packagings). The ultimate use of these overpacked drums is to proceed to the nearest appropriate disposal or repackaging facility. Salvage Drums are not to be used as a secondary container, or overpack, for a primary shipment. Recently, DOT commented that while it is their intent for these packagings to be used for damaged, defective, leaking or non-compliant packagings that have already entered transportation, it is also their intent to limit the use to when packagings are discovered to be non-conforming after having been placed in transportation.