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

Archive for October, 2019

What to do when the DOT Inspector Arrives at Your Door!

October 29th, 2019 by Howard Skolnik

Filed under: DOT/UN, Skolnik Newsletter

Before an inspection, all companies should establish procedures for dealing with visits by a regulatory inspector. These procedures should address a policy on taking pictures and/or recording interviews in the facility as well as security requirements. Inspections are random and unannounced. An important step in the procedure is to establish a primary and alternate contact to be responsible for interacting with any hazardous materials inspector. The primary contact should be aware of all applicable hazardous materials regulations, know where appropriate documents, such as training materials, are stored, and is knowledgeable about the basic requirements of an inspection. Important procedures to have in place include:

  1. Store applicable training certificates/materials in an easily accessible location: Evidence of training is often looked at during an inspection. Make sure that that everyone who signs shipping papers has a corresponding training record.
  2. Store applicable shipping documents in an easily accessible location: Shipping documents are often referenced and analyzed during an inspection. It is important to note that regulatory agencies only require the review of shipping papers from a certain timeframe. Any shipping documents retained beyond that timeframe should be kept in a separate location.
  3. Keep non-dangerous goods shipping documents separate from dangerous goods shipping documents.
  4. Keep any applicable regulatory manuals at the company shipping desk. These manuals should be the most current version of the regulations.
  5. Have a designated location/isle within your facility or warehouse where hazardous materials are stored. Many inspectors will want to look at how hazardous materials are stored, packaged, labeled, marked and otherwise handled prior to transport. Having these materials in a central location helps streamline the inspection process.

When an inspector arrives, it is important that the primary contact stays with the inspector as much as possible throughout the visit. The primary contact should make sure to do the following:

  1. Invite the inspector to a conference room or private office.
  2. Identify the inspector: Ask to see credentials. Write down relevant information.
  3. Determine the scope of the inspection. Ask the inspector what initiated the inspection.
  4. Advise the companies’ legal counsel of the presence of the inspector.
  5. Take notes on what is seen, what is said, by whom, and whether any samples or copies of documents are taken.
  6. When in doubt on any question posed by the inspector, do not answer. Communicate to the inspector that you do not understand the question, and ask the inspector to put the question in writing, addressed to you company counsel or designated contact. Provide them with the companies’ counsel information.
  7. Do not admit to any violation or lack of compliance verbally or in writing. Do not sign anything other than an acknowledgement that the inspector was there.
  8. Prepare a memo as soon as the inspector leaves. It should include all relevant details of the inspection, copies of documents produced or requested, etc.

At the end of the inspection, the officer will give you details regarding the outcome of the inspection and suggestions of how the company can address concerns that were highlighted.
This is normally a very fair process that helps UN shippers comply with regulatory aspects of their shipments.

Can you Interpret the Marking on the Bottom of your Drum?

October 22nd, 2019 by Howard Skolnik

Filed under: DOT/UN, Skolnik Newsletter

Every UN certified drum has a “birthmark” but few shippers know the meaning of these markings. In accordance with UN recommendations, certified markings indicate the performance rating and test information about a steel drum and must be applied in accordance with CFR 178.3(a)(3). For drums over 100 Litres (26 US Gallons) there are a number of ways that the marking can be applied including stamping, embossing, burning and printing. For these size drums, there must be one complete set of durable marks on the side or non-removable top head of a closed head drum, and a second, partial mark, embossed permanently on the bottom head. The purpose of having the two marks is that once filled, the drum will sit, primarily, on its bottom head, and the UN test information needs to be readily viewable for the user at the side or top mark. The permanent partial bottom mark must conform to the application options indicated earlier. However, the side or top mark is required to be durable rather than permanent. Therefore, it is common and acceptable for the durable mark to be printed on a self-adhesive label, which is attached to the side of the drum. The characters on the label and the permanent embossment are subject to the size and sequence requirements as specified in 178.3(4) and 178.503(a)(1) through (a)(6) and (a)(9)(i). For a breakdown of the individual marks, you can link to the following:
Open Head Solid Marking, Open Head Liquid Marking, Closed Head Marking, Seamless Marking.

That’s Not an Overpack Drum

October 21st, 2019 by Natalie Mueller

Filed under: Industry News

If you’re advised to use an overpack drum in a spill situation, that’s not an overpack drum. If you’re sold a liquids-certified overpack drum, that’s not an overpack drum. Or, if it is, you aren’t using it in the way it was designed or certified to be used and your noncompliance could result in a nasty fee, or, worse yet, a dangerous mess. That’s because overpack drums and salvage drums are designed and tested differently.

An overpack drum is a container that makes handling a package or multiple packages easier. A condition of using an overpack drum is that the items or packages it contains cannot be damaged or leaking. Overpack drums are not certified for liquids or to hold damaged packages. The container inside an overpack drum must be intact. Overpack drums are often used as a preventative measure to keep the inner package from leaking or enduring any dents or dings, but if the damage is already done, it’s too late for an overpack to compliantly save you.

So what do you do if the packages you need to contain are leaking? Call on a trusty salvage drum. Salvage drums are designed to contain leaking, damaged or otherwise non-compliant drums, even if they contain hazardous materials. And there is such a thing as a liquids-certified salvage drum.

Some resources use the terms overpack and salvage interchangeably, but it is important to note that they are not. And making that mistake can be costly.

“Hey Alexa, will you pour me a glass of Riesling?”

October 15th, 2019 by Jon Stein

Filed under: Skolnik Newsletter, Wine

In a recent Wine Advisor report, details emerged about Travel Oregon launching an innovative voice search game using Amazon’s Alexa device. Why Oregon? Because Oregon is home to more than 760 wineries and 19 distinct growing areas, making it one of the largest wine-grape-producing states in the nation. It’s tough for even the biggest Oregon wine aficionados to know everything about Oregon wine. That’s why Travel Oregon created the new “Oregon Wine Quiz” for Alexa users to test their wine knowledge. Whether you’re a novice or a connoisseur, the quiz highlights some of the undiscovered facts about the Oregon wine landscape and tells the deeper story of Oregon wine. It’s estimated that by 2020, 50% of all searches will be voice searches. Currently 17% of American households have a smart speaker installed. By 2022, this number is anticipated to increase to 66%. The shift to voice search has already begun. The “Oregon Wine Quiz” is a way for Travel Oregon to integrate tourism marketing and voice search and stay ahead in the ever-changing media landscape.

“We need to keep evolving and expanding our content platforms if we‘re going to remain relevant to our target audience,” said Mo Sherifdeen, Global Integrated Marketing Director at Travel Oregon. “We’re thrilled to be the first tourism agency in the country to experiment with distributing content through voice search. But more importantly, we’re excited to give wine enthusiasts another way to learn about Oregon wines before they head out to wine country this fall.”

To activate the quiz, simply ask Alexa to “play the Oregon wine quiz.” Users will then be asked a series of questions about Oregon wine. Depending on the answers, users will unlock one of four podcasts, featuring interviews and storytelling from some of Oregon’s most prominent wine industry professionals, including: Travel Southern Oregon, Abacela, Brooks Winery Troon Vineyards, Tuality Healthcare and Willamette Valley Vineyards.

The topics covered include: community winemaking, The Applegate Valley Wine Trail, and sustainable winemaking. This Alexa application was built by Portland-based agency, Sparkloft Media with content support from the Oregon Wine Board. Are you ready to take your Oregon wine knowledge to the next level? Take the quiz today. And, no, Alexa can’t pour you a glass of Oregon Riesling yet, but here at Skolnik Industries, you can ask us about our stainless steel wine barrels. They are reusable, easy to clean, and recyclable at the end of their service life. Check out the full line of our Stainless Steel Wine Drums here.