A compliant shipment of dangerous goods has never been more critical, more complex and more expensive if done improperly. In addition to lives at risk, planes, ships, trains, trucks and all public right-of-way can be severely impacted when an incident does occur. In order to educate shippers on how to identify, pack and ship hazardous materials, many agencies and industry partners are developing resources to provide the latest in safety regulation as well as videos and tools on how to transport products safely. The Council on Safe Transport of Hazardous Articles (COSTHA), has gathered this information and created a web page that is an outstanding resource for learning about compliant shipping of dangerous goods / hazardous materials. Check out the webpage and learn how you can help to ensure that regulated shipments in commerce are properly prepared.
Drum It Up! Steel Drum Industry News, Trends, and Issues
Archive for the ‘Associations’ Category
For many years, during DOT audits, customers are often asked to provide technical information regarding the prevention of the closure plug Back-Off. By definition, Back-Off refers to the potential loosening of a steel or synthetic drum plug (usually the 2” and the ¾” on the top head) after the required torque is reached when closing a drum. Currently, CFR 49, 173.227(b)(2)(ii) does state that the screw closures must be “physically held in place by any means capable of preventing back-off or loosening of the closure by impact or vibration during transportation.” Transport Canada still refers to this requirement as “closures that are threaded.” However, in a move to have Transport Canada harmonize with the US CFR, COSTHA (The Council on the Safe Transport of Hazardous Articles) has submitted a proposed revision to Transport Canada. The proposal expands the criteria so that the “inner packagings shall have closures with gaskets and which shall either be threaded or physically held in place by any means capable of preventing back-off or loosening of the closure by impact or vibration during transport.”
For information about meeting the Back Off requirement, Skolnik offers solutions to securing closures plugs.
Members of the Council on the Safe Transport of Hazardous Articles (COSTHA) met for the quarterly review of the domestic and global dangerous goods (DG) issues. On October 3-5, 2017, in Rosemont, IL, about 100 COSTHA members attended the event. Of particular interest, the new eCommerce Committee, Chaired by Veronica Wilson, identified the need for a forum for following the DG issues related to shipments via ground which are primarily business to business (B2B) and business to consumer (B2C). Wilson identified that the initial scope of the Committee would not address matters related to shipments from private companies, such as eBay, shipments of counterfeit products, lithium batteries, nor reverse logistics. While important topics that will later be addressed, the primary scope at this time would be related to DG markings and labels on packagings. One of the members offered that a separate initiative has been launched by UL where air carriers would be able to search a database of battery manufacturers to confirm if they have passed the UN 38.3 test and help identify counterfeit and/or unsafe batteries from being transported.
The Packaging Committee, Chaired by Tracie Cady, reviewed the current list of issues to present to the Pipeline and Hazardous Materials Safety Administration (PHMSA), which included the ability for Third-Party Test Labs to test and mark foreign packagings. The Committee also agreed to monitor a developing situation of counterfeit markings on packagings (ie, markings applied to unqualified packagings and contents by unknown manufacturers). COSTHA members will reconvene in Alexandria, VA, January 9-10, 2018 for Committee updates and regulatory presentations.
On April 26th, 2017, the US House Transportation and Infrastructure Subcommittee on Railroads, Pipelines and Hazardous Materials held a subcommittee hearing (Chairman Jeff Denham, R-Calif.) on “Building a 21st Century Infrastructure for America.” Addressing the State of Railroad, Pipeline, and Hazardous Materials Safety Regulations and Opportunities for Reform, Paul Rankin, COSTHA member and President of the Reusable Industrial Packaging Association represented the IP Group. The IP Group is an informal coalition of 45+ associations that meet on a regular basis in Washington DC.
Members of the Interested Parties strongly support a robust and efficient hazardous materials transportation regulatory program. Industry recognizes the benefits of a centralized regulatory agency within the Department of Transportation (DOT) that has cross-modal and international authorities. Safety is of paramount importance to industry and the exemplary record in this area, and support for effective regulation, underscore this goal. In his testimony to the Subcommittee, Paul addresses: the Importance of Reasonable Federal Regulation in the Field of Hazardous Materials Transportation, Preemption, Programmatic Authority, Special Permits and Approvals, International Affairs, Enforcement, PHMSA Office of Planning and Analytics, Incident Reporting, and General Regulatory Reform.
To view the video of the hearing –
Paul Rankin begins his testimony at 28:45.
To read Paul’s testimony –
May 2nd, 2017 in Scottsdale, AZ – At the annual meeting of the Council on the Safe Transport of Hazardous Articles (COSTHA), William (Bill) Schoonover, Associate Administrator for Hazardous Material Safety at the US DOT Pipeline and Hazardous Materials Safety Administration (PHMSA) presented the Vision and Mission of PHMSA. Their Vision is to be the most innovative transportation safety organization in the world, and their Mission is to protect people and the environment by advancing the safe transportation of energy and other hazardous materials that are essential in our daily lives.
PHMSA will achieve these goals by investing in people, increasing communication internally and externally, positioning for innovation, fostering transparency and improving engagement. This will be achieved by implementing a safety management system that is data driven from information gathered from the 45,000 companies overseen by DOT. This information, and implementation, will include electronic shipping papers, new hazmatics which will improve how data is collected, and the beginning of regulation and data collection of autonomous vehicles. In addition, PHMSA will be the first government agency to have an ISO 9000 certified data collection system.
In addition to Mr. Schoonover, Ryan Pacquet, Director of Approvals and Permits; Shane Kelley, Assistant International Standards Coordinator; and Lindsey Constantino, International Transportation Specialist, also addressed the COSTHA members on the PHMSA strategies for the near future.
Some persons in corporate management believe that outsourcing the corporate transportation function will help to insulate the company from liability in the event of a motor carrier accident or a hazardous materials incident. This is not necessarily true — outsourcing to third parties does not necessarily eliminate or mitigate this risk. Outsourcing transportation to a for-hire motor carrier (or an intermediary such as a broker or freight forwarder) does change the target of due diligence from private fleet drivers to the third party transportation provider, but it does not eliminate the shipper’s responsibility for investigating the person or company that will be transporting their goods, performing their pre- and post-transportation functions adequately, or even supervising their carrier’s performance. But the aggressive exercise of management over carrier practices could also provide evidence that the shipper is responsible for the carrier’s negligent acts or omissions. Ultimately, shippers must balance the need to control their transportation service and the acceptance of a certain degree of liability for injuries caused by transportation operations.
To further investigate these liabilities, Richard (Rick) Schweitzer, General Counsel to the Council on the Safe Transportation of Hazardous Articles (COSTHA), and General Counsel to Skolnik Industries, has prepared a paper entitled Downstream Liability: Myths Versus Reality. This paper deals with civil liability for incidents or collisions that cause personal injuries or death and that occur in the stream of commercial motor vehicle transportation. View the entire paper here.